Introduction: The Growing Complexity of 1095-C Compliance

In 2025, the IRS has eased the federal requirements for distributing Form 1095-C, allowing employers to issue them only upon request. However, several states continue to enforce stricter mandates requiring automatic distribution. This evolving compliance landscape presents a unique challenge for employers, especially those with remote or multi-state workforces.

This article breaks down:

• The latest federal changes
• State-specific mandates
• Compliance risks
• How services like ACA COMPLIANCE SOLUTION SERVICES can support streamlined, penalty-free reporting

Federal Rule Update: "Upon Request" Provision

What Changed?

For the 2024 reporting year (filed in 2025), the IRS allows Applicable Large Employers (ALEs) to:

• Distribute Form 1095-C only upon employee request
• Provide a clear public notice (website or intranet) by March 3, 2025, that instructs employees on how they may request their form
• The notice stays posted through October 15, 2025
• Deliver the form within 30 days of the request or by January 31 the following year, whichever is later
• Rely on one-time employee consent for electronic delivery

Goal of the Change

This update is aimed at reducing paper usage and administrative burdens for employers.

State-Level Mandates: Where Automatic Distribution Is Still Required

Although several states require ACA reporting to be filed at the state level, California stands out as the only state that enforces stricter requirements when it comes to furnishing forms to employees:

• Requires: Public notice must be posted by January 31, 2025, but can chose alternative methods of furnishing (i.e. Electronically)
• Also Requires: Filing forms with the Franchise Tax Board
• Deadline: March 3 (distribution), March 31 (filing)

Compliance Risks: Why It Matters

Failing to meet state-specific mandates can result in:

• Financial penalties ($50+ per form in many states)
• Audit risk and legal exposure
• Employee confusion and HR challenges

State non-compliance risks are not mitigated by following federal rules alone.

How ACA Compliance Solution Services Supports ACA Compliance

ACA Compliance Solution Services, Inc. offers full-service ACA and 1095-C compliance solutions tailored for complex, multi-state reporting:

Services Offered:

• End-to-end 1094/1095-C preparation and filing
• State-specific compliance management (CA, NJ, RI, DC)
• Penalty mitigation and IRS response services
• ERISA wrap plans, POP plans, and more

Benefits:

• Reduces risk of fines and audits
• Automates delivery and tracking
• Supports remote/hybrid workforce compliance

ACA Compliance Solution Services offers white-glove service to ensure a stress-free filing experience

Employer Action Plan: 1095-C Compliance Checklist

Use this checklist to stay compliant with both federal and state rules:

• Identify employee locations, including part-year or remote workers
• Review applicable state mandates (CA, NJ, RI, DC)
• Publish IRS-required notice for federal "upon request" compliance by March 3
• Automatically distribute 1095-Cs where state law mandates
• Ensure electronic delivery consent is documented
• File state forms by deadlines (March 31 or April 30)
• Maintain records of notices, distributions, and filings

Stay Ahead of the Compliance Curve

While the IRS has taken steps to reduce ACA compliance burdens, states like California, New Jersey, Rhode Island, and D.C. continue to require proactive 1095-C management. Employers who ignore these dual obligations risk penalties and operational setbacks.

Partnering with experienced ACA compliance experts like ACA Compliance Solution Services helps ensure you're prepared—no matter where your employees work.

Need help with ACA compliance or want to discuss your company’s specific situation?Contact us at (877) 959-3953 x222, email This email address is being protected from spambots. You need JavaScript enabled to view it. or visit us at acacss.com com to explore full-service solutions tailored to your workforce.