IRS Releases Draft 2026 Form 1095-C

The IRS has released a draft version of the 2026 Form 1095-C, providing employers and ACA reporting vendors with an early look at next year’s reporting requirements. For most employers, the draft form will look familiar—it contains few substantive changes from the version used for 2025 reporting.

What Form 1095-C Reports

Form 1095-C is used by applicable large employers (ALEs) to report offers of health coverage to full-time employees and to help the IRS administer the Affordable Care Act’s employer shared responsibility provisions. Employees may also use information reported on the form when determining eligibility for premium tax credits through the Health Insurance Marketplace.

The draft form continues to include all existing ACA offer-of-coverage codes on Line 14, including codes associated with Individual Coverage Health Reimbursement Arrangements (ICHRAs). These codes address affordability determinations based on an employee’s residence ZIP code or primary worksite ZIP code. Several reporting codes remain reserved for future use, suggesting no significant coding changes are expected for 2026.

Why Now Is a Good Time to Review ACA Compliance

Although the form itself appears largely unchanged, the release of the draft is a timely opportunity for HR and benefits teams to review their ACA reporting processes:

• Full-time employee measurement and tracking procedures
• Coverage offer documentation
• ACA affordability testing methodologies
• Payroll and enrollment data accuracy
• Reporting processes and coding practices

Recent increases to employer shared responsibility penalties mean that inaccurate reporting, coding errors, or eligibility tracking mistakes can become increasingly costly. Maintaining accurate employee records and ACA-compliant processes remains important regardless of how much the form changes year to year.

BAS provides ACA Data Collection and Reporting services to help employers track eligibility, document coverage offers, and meet annual filing requirements accurately. For more information, contact your account manager or reach BAS at solutions@basusa.com.