Short answer: Not always.

Starting with the 2024 tax year, employers no longer have to automatically send Form 1095-C to every full-time employee. Instead, they only need to send it if the employee asks for it—but only if certain steps are followed.

What Changed?

Two new laws passed in late 2023 changed how employers handle ACA (Affordable Care Act) reporting:

• Employers can now only send Form 1095-C upon request
• But they must tell employees how to request it

What Employers Need to Do

To use this new “on-request” option, employers must:

1. Post a Notice Online

The company website or employee portal must include a clear message that:

• Tells employees they can ask for Form 1095-C
• Explains how to request it
• Stays on the website until October 15, 2025

2. Send the Form on Time

If an employee asks for Form 1095-C, the employer must send it by:

• January 31 of the next year, or
• Within 30 days of the request—whichever is later

Why This Matters

If employers don’t follow these rules, they could face IRS penalties. Non-compliance could also cause:

• Delays or confusion for employees filing taxes
• IRS audits or questions
• Problems with state requirements (like in California, New Jersey, and others)

What Employers Should Do Now

• Check your website – make sure the 1095-C request info is posted clearly
• Make a plan to track and respond to employee requests
• Work with HR and payroll to make sure everything is in place
• Keep records – save request and delivery info for 7 years