Start ACA reporting by identifying what your organization must file and which records support that obligation. These guides help employers and coverage providers choose the correct forms, define the reporting population and coordinate preparation, filing and furnishing.
Choose the form family from the reporting obligation
An ALE member generally uses Forms 1094-C and 1095-C for required employee reporting. A non-ALE employer sponsoring self-insured coverage generally uses Forms 1094-B and 1095-B for its coverage reporting. Insured enrollment is generally reported by the responsible carrier, while an ALE member can still have independent C-series offer-reporting duties.
Use the 2025 B-series instructions and 2025 C-series instructions to review funding arrangements, nonemployees and special cases. Form 1095-A generally concerns Marketplace reporting; an employer does not create a substitute A form for an employee's individual Marketplace coverage.
Document the employer and provider assignments
| Arrangement | Employer work | Other party to coordinate |
|---|---|---|
| ALE member with insured plan | C-series employee offer reporting | Carrier's insured enrollment reporting |
| ALE member with self-insured plan | C-series and applicable Part III enrollment | Administrator source data and any filing provider |
| Non-ALE self-insured employer | B-series coverage reporting | Administrator and designated preparation provider |
| Non-ALE insured employer | Confirm applicable obligations and service assignments | Carrier's coverage reporting |
The matrix describes common cases, not every reporting exception. A vendor may perform preparation or transmission without changing the identity of the responsible filer. Confirm the form, year, covered period and expected completion evidence for each assignment.
Build the complete business reporting population
Reconcile employment history, ACA full-time determinations, plan offers, waivers and applicable covered-individual records. An enrollment list alone can omit full-time employees who declined coverage, while a payroll list can omit dependents or other required covered people.
Count employee returns and covered-person rows separately. Document duplicate source profiles, special populations and exclusions before approving the filing set. Keep the final population version with the generated records so the business can explain any later addition or correction.
Resolve data errors where they originate
Trace discrepancies from authoritative source records to preparation mappings, rendered statements and any filed records. Assign identity questions to HR, rate questions to benefits and enrollment questions to the responsible coverage source. The reporting approver determines the required form treatment.
If an import drops a class of coverage changes, identify all affected people and returns. Correcting one PDF does not repair the source problem or update a filed agency record. Reconcile the repaired output and choose the release procedure that fits the actual filing status.
Complete filing and employee-statement service separately
Record agency filing and acknowledgment outcomes independently from statement delivery. If the organization uses the alternative manner of furnishing under Notice 2025-15, meet the notice and timely-response requirements while continuing to fulfill the IRS filing obligation.
Give HR a clear copy-request and inquiry process. Retrieve the appropriate approved version for a reprint, investigate actual reporting omissions and route another issuer's statement request to that organization. A request for a copy should not produce a duplicate original filing.
Business filing FAQs
Are 1095-B and 1095-C interchangeable?
No. Select the form family based on the responsible reporting organization, employer status, funding arrangement and population. An ALE member's offer reporting and a carrier's coverage reporting serve different obligations.
Does using a filing provider remove the employer's responsibility?
No. Confirm who prepares, approves and transmits each output while preserving the responsible filer's identity. Retain source, approval and completion evidence for the employer's reporting project.
Should every dependent receive a separate employee return?
No. Apply the relevant covered-person reporting rules and enrollment relationships. Employee-return counts and covered-individual counts are different measures and should be reconciled separately.
Can we stop filing because statements are available on request?
No. The alternative furnishing method changes how eligible statements are furnished when its requirements are met. It does not eliminate the required IRS information-return filing.
Prepare the business filing
Use the employer guides below to establish the form family, reconcile populations, assign provider duties and manage data exceptions. Review BoomTax's ACA filing options after the business reporting requirements are defined.
