IRS Notice 2025-15
IRS Notice 2025-15 explains how employers can furnish Forms 1095-C on request instead of mailing them to every employee, following the Paperwork Burden Reduction Act.
What it says and why it matters.
The Alternative Manner
An employer can post a clear, conspicuous and accessible notice that employees may request a copy, and furnish the form within 30 days of a request.
Timing
The notice has to be posted by the furnishing deadline and kept up through October 15 of the year the form is due.
What It Does Not Change
Filing with the IRS is unchanged, and state mandates that require furnishing are not overridden by the federal relief.
Primary source: IRS Notice 2025-15. General information, not legal advice.
A worked example.
Posting the Notice
An employer posts a notice on its HR portal on February 20 saying that any employee may request a copy of Form 1095-C and that copies will be sent within 30 days.
What the Rule Produces
The notice is up before the March 2 deadline and stays up through October 15. When an employee asks on April 3, the employer furnishes the form by May 3.
Four steps to apply it.
1. Draft the notice
Short and clear.
2. Post it
Where employees can find it.
3. Keep it up
Through October 15.
4. Respond
Within 30 days.
Where it goes wrong. Burying the notice where former employees cannot find it.
The questions that come up next.
Do we still need to file with the IRS?
Yes. Forms 1094-C and 1095-C are still filed by the IRS due dates.
Can the notice be on a website?
Yes, if it is accessible to all intended recipients, including former employees and retirees where applicable.
Which years does it apply to?
It is effective for returns for calendar years beginning after 2023.
Does it replace mailing for everyone?
It lets you furnish on request instead of mailing to all.
What if a state requires mailing?
Follow the state rule.
Plan-specific questions belong with ERISA counsel, and we will bring them in.
Related sources and guides.
IRS Employer Shared Responsibility Provisions
The IRS publishes an overview of the employer shared responsibility provisions.
26 CFR § 301.6011-2
Section 301.6011-2 requires electronic filing of certain information returns once a filer has 10 or more returns.
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