IRS Pub 5223 – IRS Forms, Instructions, Pubs 2026 – In the complex world of tax compliance, staying updated with IRS guidelines is crucial for employers, insurers, and software developers handling Affordable Care Act (ACA) reporting. IRS Publication 5223, titled “General Rules and Specifications for Affordable Care Act Substitute Forms 1095-A, 1094-B, 1095-B, 1094-C, and 1095-C,” serves as a key resource for ensuring accurate substitute form creation and submission. This article breaks down the publication’s core elements, using the latest information from official IRS sources as of February 2026. Whether you’re preparing forms for tax year 2025 or seeking clarity on substitute form requirements, we’ll cover everything you need to know.
What is IRS Publication 5223?
IRS Pub 5223 outlines the standards for creating and using substitute versions of official IRS forms related to ACA information reporting. These forms are essential for reporting health coverage details to the IRS and recipients, helping ensure compliance with Sections 6055 and 6056 of the Internal Revenue Code. The publication is particularly relevant for software vendors, form producers, and filers who need to generate non-official replicas that meet IRS scanning and processing criteria.
The latest revision of Pub 5223 is dated November 2025, with an effective date of January 29, 2026, applying to tax year 2025 filings. It’s available as a free PDF download directly from the IRS website, making it accessible for anyone involved in ACA reporting.
Purpose of IRS Pub 5223
The primary goal of this publication is to establish requirements for:
- Filing information returns using official IRS forms.
- Creating acceptable substitute forms for IRS submission.
- Furnishing information to recipients via official or substitute forms.
It focuses on forms like 1095-A (Health Insurance Marketplace Statement), 1094-B (Transmittal of Health Coverage Information Returns), 1095-B (Health Coverage), 1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns), and 1095-C (Employer-Provided Health Insurance Offer and Coverage). By adhering to these rules, filers avoid penalties and ensure smooth processing.
What’s New in the Latest Version?
The November 2025 revision includes updates tailored to tax year 2025, such as clarifications on the alternative manner of furnishing Form 1095-B. While no major overhauls are noted, it emphasizes ongoing requirements like electronic delivery consents and truncation rules for identification numbers. For the most current developments, check the IRS page for Pub 5223, as no recent changes were reported as of early 2026.
General Rules for Substitute Forms
Substitute forms must closely mirror official IRS versions to be acceptable. Key general rules include:
- Conformity and Approval: Exact replicas don’t require prior approval but must be submitted in blank PDF format to [email protected] for scanning preparation. Non-exact substitutes need a source code if they differ significantly.
- Prohibited Elements: No logos, slogans, or ads on IRS-filed copies, except for non-intrusive employer names or trademarks. Avoid “IRS approved” statements.
- Truncation of IDs: Recipient SSNs/ITINs can be truncated (e.g., XXX-XX-1234) on statements, but not on IRS filings. Employer EINs on Form 1095-B can be truncated on recipient copies.
- Furnishing to Recipients: Statements must include instructions and can be delivered electronically with consent. An alternative method for Form 1095-B involves posting a website notice instead of mailing.
- Penalties for Non-Compliance: Fines range from $60 to $340 per return, depending on correction timing, with caps for small businesses.
- Paper and Ink Standards: Use high-quality OCR bond paper (18-20 lb) with specific opacity, thickness, and ink reflectance for scannability.
These rules ensure forms are readable by IRS systems and compliant with privacy standards.
Specific Specifications for Each Form
Pub 5223 provides detailed specs for layout, typography, and content to facilitate accurate scanning:
- Form 1095-A: Covered under general truncation and electronic rules, but no form-specific exhibits; follows similar standards as others.
- Form 1094-B and 1095-B: Landscape format, Helvetica bold 10-point font for fields, OCR A for form ID codes. Includes continuation sheets for multiple entries.
- Form 1094-C and 1095-C: Multi-page specs with check boxes in 10-point font, 1/8 inch white space. Requires precise positioning of data elements.
| Form | Key Specifications | Exhibit Reference |
|---|---|---|
| 1094-B | Form ID 560118, nonreflective black ink, 1/2 inch margins | Exhibit A |
| 1095-B | Page 1 and continuation (Page 3), 6 lines/inch, no proportional fonts | Exhibits B & C |
| 1094-C | Pages 1-3, fillable fields in Helvetica, actual size printing | Exhibits D, E, F |
| 1095-C | Page 1 and Page 3, OCR bond paper requirements | Exhibits G & H |
All forms must include OMB numbers and Privacy Act notices exactly as on official versions.
Requirements for Software Developers and Form Producers
Software developers must:
- Submit blank substitute forms to [email protected] for review.
- Ensure no “live” taxpayer data is included in submissions.
- Use approved typography (e.g., Helvetica) and avoid overstocking outdated forms, as specs are reviewed annually.
This helps prevent processing errors and ensures compatibility with IRS systems.
Approval Processes and Inquiries
- Exact Replicas: No formal approval needed; just forward blanks to SCRIPS.
- Non-Exact Substitutes: Email [email protected] for source codes or clarifications, including examples.
- Mailing Option: Send inquiries to the IRS Substitute Forms Program in Washington, DC, allowing 30 days for response.
Important Deadlines for ACA Substitute Forms
Compliance timelines are critical to avoid penalties:
| Deadline | Description |
|---|---|
| March 3, 2026 | Post website notice for alternative Form 1095-B furnishing (includes 30-day extension). |
| Within 30 Days of Request | Furnish Form 1095-B upon recipient request. |
| October 15, 2026 | Electronic statements must remain accessible online until this date. |
| Varies by Form | General filing due dates per form instructions; electronic filing required for 10+ returns. |
Always refer to the specific form instructions for exact dates.
Download IRS Pub 5223 PDF
To access the full details, download the official IRS Publication 5223 PDF here: https://www.irs.gov/pub/irs-pdf/p5223.pdf. This direct link from the IRS ensures you have the most current version for tax year 2025.
Conclusion
IRS Pub 5223 is an indispensable tool for navigating ACA substitute form requirements, helping you maintain compliance and efficiency. By following its guidelines on specifications, approvals, and deadlines, you can minimize errors and penalties. For personalized advice, consult a tax professional or visit IRS.gov for updates. Stay informed to make ACA reporting seamless in 2026 and beyond.