You May Not Have to Mail 1095-Cs Anymore. Here Is the Catch.
The Paperwork Burden Reduction Act lets employers post a notice instead of mailing every 1095-C. Andrew Smith walks through exactly what the notice has to say, when it has to be up, and why the IRS filing has not gone anywhere.
For ten years, the first week of March meant stuffing envelopes with Forms 1095-C. Starting with the forms for 2025, that is optional, and I want to be precise about what optional means, because I have already seen two employers get it half right.
What the law did
The Paperwork Burden Reduction Act, with the IRS following in Notice 2025-15, lets applicable large employers use an alternative furnishing method. Instead of mailing a 1095-C to every full-time employee, you post a clear and conspicuous notice telling employees the form is available on request.
What the notice has to include
This is where people get sloppy. The notice has to be posted on your website or wherever employees would reasonably look, by the furnishing deadline, which is March 2 this year. It has to stay up through October 15. It has to include an email address, a physical mailing address, and a phone number employees can use to request their form. And when someone asks, you have to provide the form within 30 days of the request or by January 31, whichever is later.
A line buried in the employee handbook does not meet that standard. A notice on the intranet home page or the benefits portal does.
What did not change
You still file the 1094-C and all of the 1095-Cs with the IRS. The electronic filing deadline is March 31. The alternative method only changes what you send to employees, not what you send to the government. If you skip the IRS filing because you heard the forms were no longer required, you will get a 226-J letter, and those are not fun.
Also check state law. A handful of states with their own individual mandates still require furnishing. Florida is not one of them, but if you have employees in California, New Jersey, Massachusetts, Rhode Island, or the District of Columbia, confirm those rules separately.
Should you switch
For most of our clients, yes. The forms are still being generated, so the only savings are postage and the Monday after they land, when HR answers the same question forty times. Fewer forms in the mail means fewer questions. Just make sure someone owns the notice, the request inbox, and the 30-day turnaround, and that whoever prepares your 1095-Cs knows you are using the alternative method so the forms are ready on demand.
This is general guidance and not legal advice. If you want us to review your notice language before March 2, send it over. It takes ten minutes.
This article is for general informational and educational purposes only and does not constitute insurance, legal, tax, or financial advice. For guidance specific to your organization, talk with an FBP advisor.
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