IRS Extends ACA Reporting Relief for NY Employers in 2025

New York employers face significant changes to their ACA reporting obligations following recent federal legislation that reduces administrative burdens while maintaining critical compliance deadlines. The Paperwork Burden Reduction Act (H.R. 3797) and Employer Reporting Improvement Act (H.R. 3801) have fundamentally altered how businesses handle Forms 1095-B and 1095-C distribution.

What the Law Requires

Under the new federal regulations, employers are no longer required to automatically distribute Forms 1095-B and 1095-C to all covered employees. According to the IRS, these forms now only need to be provided upon employee request for calendar years beginning after 2023. Additionally, employers can now distribute these forms electronically with employee consent, streamlining the process significantly.

However, the March 31, 2025 deadline for electronic filing remains firm. Employers must still file Forms 1094-C and 1095-C with the IRS by this date, regardless of the distribution changes.

Impact by Business Size

• Small businesses (under 50 employees): Those offering self-insured health plans still face reduced administrative costs from optional employee distribution, potentially saving $200-500 annually in printing and mailing costs.
• Mid-size companies (50-500): Face the most significant compliance relief, with potential savings of $1,000-3,000 per year while maintaining full ACA reporting obligations to the IRS.
• Large employers (500+): Can realize substantial administrative cost savings of $5,000+ annually while streamlining HR processes through electronic consent systems.

Compliance Deadlines

The critical date for NY employers is March 31, 2025, for electronic filing of all required ACA forms with the IRS. While employee distribution is now request-based, employers must maintain systems to provide forms within 30 days of any employee request. Combined with other 2025 New York labor law changes, businesses need comprehensive compliance strategies.

Next Steps

Review your current ACA reporting processes immediately and implement request-based distribution systems. Update employee communications to explain the new process and establish electronic consent procedures where beneficial. Ensure your payroll and benefits administration systems can meet the March 31 electronic filing deadline. Benton Oakfield's compliance team can help you navigate these ACA reporting changes and ensure your business stays compliant while maximizing cost savings. Contact us to review your policies and streamline your 2025 reporting obligations.

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