Federal
Benefits
ACA reporting relief: you may not have to mail every 1095-C
Posted 1/20/2026
Effective 1/20/2026
The Paperwork Burden Reduction Act lets applicable large employers use an alternative furnishing method for Forms 1095-C — post a clear notice and provide the form on request instead of mailing to every employee.
What changed
Public Law 118-167 (the Paperwork Burden Reduction Act) permits applicable large employers to satisfy the Form 1095-C furnishing requirement by providing clear, conspicuous and accessible notice that employees may request a copy, and then delivering the form on request by the applicable deadline. The IRS filing obligation itself is unchanged.
Who it applies to
Applicable large employers — 50 or more full-time equivalent employees.
What HR needs to do
- Decide whether to adopt the alternative method. Mail volume savings are real, but only if the notice is posted correctly and by the deadline.
- Draft the notice with the required content and place it where employees actually look, not buried in a portal.
- Build a request intake process with a tracked turnaround, and keep proof of delivery.
- Keep IRS e-filing on schedule; the electronic filing threshold still catches most employers.
- Check state-level reporting separately. California, New Jersey, Massachusetts, Rhode Island and DC have their own mandates and their own rules.
Read the source HRISHQ summarizes legal developments for HR practitioners. It is not legal advice — confirm specifics with counsel before acting.