This checklist is intended to help an Applicable Large Employer comply with federal Affordable Care Act reporting rules when furnishing Form 1095-C to employees, former employees, and, where applicable, other individuals through electronic delivery with consent or the on-demand request method.
Key Federal Deadlines
- For 2026 calendar-year reporting, furnish Form 1095-C directly, or post the required availability notice if using the on-demand method no later than March 2, 2027.
- If using the on-demand method, provide a requested Form 1095-C no later than the later of January 31, 2027, or 30 days after the request is received.
- If using the on-demand method, keep the required website notice available through at least October 15, 2027.
- File Forms 1094-C and 1095-C with the IRS by March 31, 2027, if filing electronically.
- Confirm whether any state individual mandate rules require direct furnishing of forms, because state rules may be different from the federal on-demand option.
Scenario 1: Employees Are Given a Link to Access Form 1095-C Electronically
- Confirm that each employee has affirmatively consented to receive Form 1095-C electronically before relying on electronic delivery.
- Make sure the consent specifically applies to Form 1095-C; do not rely only on a general electronic disclosure consent for other employment or benefit documents.
- If consent is obtained electronically, use a process that reasonably demonstrates the employee can access the form in the same electronic format or system that will be used to furnish it.
- Provide a clear disclosure before consent is given explaining that the employee may receive a paper copy instead, how to request a paper copy, how to withdraw consent, how to update contact information, and any hardware or software requirements needed to access the form.
- Do not treat simply sending a link as compliant unless the required consent and disclosure process has been completed.
- Make the form available by the applicable furnishing deadline and ensure the link or portal is secure, accessible, and available long enough for employees to retrieve the form.
- If an electronic notice or email is returned as undeliverable, or the employer knows the employee cannot access the form electronically, furnish a paper copy by mail or hand delivery.
- Maintain records showing the employee’s consent, the required disclosure provided, the date the form was made available, and any returned or failed electronic delivery notices.
Scenario 2: On-Demand Method — Form 1095-C Furnished Upon Request After Required Notice
- Post a clear, conspicuous, and accessible notice on the employer’s website stating that individuals may request a copy of Form 1095-C.
- Make the notice easy to find and written in plain language so individuals entitled to request the form can understand how to do so.
- Include complete request instructions in the notice, including an email address, physical mailing address, and telephone number for questions.
- Post the notice no later than the federal furnishing deadline for the applicable reporting year.
- Keep the notice posted and accessible through at least October 15 of the year following the calendar year to which the form relates.
- Track all requests when received, including request date, requester name, requested tax year, delivery preference, and date the form was furnished.
- Furnish the requested Form 1095-C by the later of January 31 following the reporting year or 30 days after the request is received.
- Use paper delivery unless the individual has affirmatively consented to electronic delivery of Form 1095-C.
- Ensure the request process is not limited to current active employees with portal access and is available to other individuals who are entitled to request the form.
- Retain documentation showing the notice was posted timely, remained available for the required period, and that each request was fulfilled on time.
Recommended Compliance Controls
- Decide before the furnishing deadline which method will be used: paper, electronic delivery with consent, or on-demand furnishing.
- Review vendor, payroll, benefits administration, and website processes to confirm they support the selected method.
- Test employee and former employee access before the deadline.
- Prepare a standard response process for requests, including ownership, turnaround time, mailing procedures, and escalation points.
- Confirm whether employees in states with individual mandate reporting rules must still receive forms directly.
- Keep copies of notices, consent records, request logs, furnishing records, and IRS filing confirmations with the ACA reporting file.
Note: This checklist summarizes federal ACA Form 1095-C furnishing rules and should be reviewed against current IRS guidance and any applicable state requirements before use.
Sample ACA Electronic Delivery Consent Form
Employer Name: ________________________________
Employee Name: ________________________________
Purpose of Consent: By signing or electronically acknowledging this form, I consent to receive my IRS Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, electronically instead of by paper delivery. This consent applies specifically to Form 1095-C and does not apply to any other tax, payroll, benefits, or employment document unless separately stated.
Electronic Access: I understand that my Form 1095-C may be made available through the employer’s secure online portal, benefits administration system, payroll system, or other designated electronic delivery method. I understand that I will receive instructions explaining how to access, download, and print the form when it becomes available.
Paper Copy Right: I understand that I am not required to consent to electronic delivery. If I do not consent, or if I later withdraw my consent, Form 1095-C will not be furnished to me electronically unless I provide a new consent, and I may request a paper copy.
How to Request a Paper Copy or Withdraw Consent: To request a paper copy of Form 1095-C, withdraw this consent, or update my contact information, I must contact the employer using the following method: ________________________________. My withdrawal of consent will be effective when received and processed by the employer and will not affect any Form 1095-C that was already furnished electronically before the withdrawal became effective.
Hardware and Software Requirements: I understand that I must have access to a device with internet access, a valid email address or portal login, and software capable of viewing and printing a PDF or other electronic document format used by the employer. If these requirements change in a way that creates a material risk that I can no longer access my Form 1095-C, the employer will notify me of the change and explain how I may withdraw consent without charge.
Duration of Consent: This consent remains in effect for each year Form 1095-C is furnished electronically until I withdraw consent, the employer changes its delivery method, or the employer no longer offers electronic delivery.
Employee Acknowledgment: I affirmatively consent to receive Form 1095-C electronically. If I am providing this consent electronically, my acknowledgment demonstrates that I can access Form 1095-C in the electronic format in which it will be furnished.
Employee Signature or Electronic Acknowledgment: ________________________________
Date: ________________________________
Employer note: Keep a record of the employee’s consent, the disclosure provided, the delivery method used, and any later withdrawal or paper copy request.
This document is provided for general informational purposes only and does not provide tax or legal advice. Please contact your legal, tax, or compliance advisor if you need additional support or verification of the applicable rules. If you need support with ACA Annual Reporting, please contact us.
Name: ________________________________
Email: ________________________________
Phone Number: ________________________________
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