Forms 1095-B and 1095-C: Which Form Must Employers Provide?

Each year, employers must navigate Affordable Care Act (ACA) reporting requirements, including determining which forms must be prepared, filed with the IRS, and furnished to employees or other covered individuals. While Forms 1095-B and 1095-C both relate to health coverage, they serve different purposes and apply to different types of employers and health plans.

Understanding these distinctions can help employers avoid reporting errors and ensure compliance with ACA requirements.

What Is the Difference Between Forms 1095-B and 1095-C?

Form 1095-B reports whether an individual was enrolled in minimum essential health coverage during the calendar year. It generally identifies the covered individuals and the months they had coverage.

Form 1095-C serves two purposes. It reports whether an Applicable Large Employer (ALE) offered health coverage to its full-time employees and, for employers sponsoring self-funded health plans, also reports actual enrollment in coverage.

An ALE is generally an employer that averaged at least 50 full-time employees, including full-time-equivalent employees, during the preceding calendar year. Related employers may need to be considered together when determining ALE status.

Which Form Is Required?

The reporting obligation depends on the employer’s size and whether its health plan is fully insured or self-funded.

Employer Type	Form 1095-C	Form 1095-B
ALE with a fully insured plan	Employer reports offers of coverage to full-time employees	Insurance carrier generally reports actual coverage
ALE with a self-funded plan	Employer reports offers of coverage and actual enrollment	Generally unnecessary for the same coverage
Non-ALE with a fully insured plan	Generally not required	Insurance carrier generally reports actual coverage
Non-ALE with a self-funded plan	Generally not required	Employer generally reports actual coverage

For employers with self-funded plans, Form 1095-C includes Part III, which identifies individuals enrolled in coverage, including covered dependents.

An ALE sponsoring a self-funded plan may also have reporting obligations for individuals who were not full-time employees during the year, such as retirees, COBRA participants, and part-time employees. Depending on the circumstances, these individuals may be reported using Form 1095-B or Form 1095-C.

Must Employers Automatically Distribute Forms to Employees?

An important change to federal ACA reporting rules allows employers and other reporting entities to satisfy certain furnishing requirements without automatically mailing or distributing Forms 1095-B and 1095-C to every individual.

Beginning with the 2024 reporting year, employers were permitted to use an alternative furnishing method by posting a clear, conspicuous, and accessible notice on their website explaining that individuals may request a copy of their applicable form.

The notice must provide instructions for requesting a form and appropriate contact information. It must remain available through October 15 of the year in which the forms would otherwise be furnished.

When an individual requests a form, the reporting entity must provide it by the later of January 31 or 30 days after receiving the request.

Employers should remember that this alternative furnishing method does not eliminate their obligation to prepare and file the required forms with the IRS. State reporting and furnishing requirements may also differ from federal rules.

What Should Employers Review Before ACA Reporting Season?

Employers should confirm that their ACA reporting procedures reflect their current workforce and health plan arrangements. Important considerations include:

• Whether the employer qualifies as an ALE for the reporting year.
• Whether each health plan is fully insured or self-funded.
• Whether reporting includes retirees, COBRA participants, part-time employees, or other individuals who may require coverage reporting.
• Whether the employer will automatically distribute forms or use the alternative website notice and furnish forms upon request.
• Whether employee, dependent, enrollment, and coverage information is complete and accurate.
• Whether applicable state reporting or furnishing requirements impose additional obligations.

Employers should also coordinate with their insurance carriers and benefits administrators to understand which party is responsible for preparing, filing, and furnishing each form.

The Bottom Line

Forms 1095-B and 1095-C are not interchangeable, and the correct reporting approach depends on the employer’s ALE status, funding arrangement, and covered population.

Although federal rules now provide greater flexibility in how these forms are furnished to individuals, employers remain responsible for accurate and timely ACA reporting. Reviewing these requirements before the reporting season begins can help prevent filing errors, unnecessary form preparation, and compliance issues.