IRS Instruction 1094-B and 1095-B – In the ever-evolving landscape of health care reporting under the Affordable Care Act (ACA), understanding IRS Instructions for Forms 1094-B and 1095-B is essential for insurance providers, employers, and government agencies. These forms play a critical role in reporting minimum essential coverage (MEC) to the IRS and individuals, helping ensure compliance and eligibility for premium tax credits. This SEO-optimized guide breaks down the purpose, requirements, deadlines, and step-by-step instructions for the 2025 tax year, drawing from the latest IRS guidelines. Whether you’re a health insurance issuer, self-insured employer, or plan sponsor, staying informed can help avoid penalties and streamline your filing process.
What Are Forms 1094-B and 1095-B?
Form 1095-B, titled “Health Coverage,” is an information return used to report details about individuals covered by MEC during the calendar year. MEC includes government-sponsored programs like Medicare and Medicaid, eligible employer-sponsored plans, individual market plans, and other designated coverage types. It does not cover excepted benefits such as standalone dental or vision plans, workers’ compensation, or disease-specific coverage.
Form 1094-B acts as the transmittal form for submitting one or more Forms 1095-B to the IRS. Together, these forms help the IRS verify coverage and assist taxpayers in claiming the premium tax credit on their returns. For instance, if an individual is covered by multiple plans from the same provider in a single month, only one plan needs to be reported.
Who Must File Forms 1094-B and 1095-B?
Filing responsibility falls on entities providing MEC to individuals. Key filers include:
- Health insurance issuers and carriers: For most types of coverage, including individual market and insured employer-sponsored plans (excluding certain government programs like CHIP, Medicaid, or Marketplace-qualified health plans reported on Form 1095-A).
- Self-insured employer plan sponsors: Including government employers for nonemployees or family members, small employers exempt from employer shared responsibility, multiemployer plan participants, and entities in Multiple Employer Welfare Arrangements (MEWAs).
- Government agencies: Sponsoring programs such as Medicare Part A, Medicaid (with exceptions for optional coverages), CHIP, TRICARE, VA coverage, Peace Corps, and Nonappropriated Fund Health Benefits.
Employers subject to ACA employer shared responsibility typically use Forms 1094-C and 1095-C for self-insured plans, but Form 1095-B may apply for non-full-time employees or nonemployees. No reporting is required for supplemental coverage if it’s only offered to those already enrolled in primary MEC.
Key Filing Requirements for 2025
To comply with IRS rules, filers must gather taxpayer identification numbers (TINs) for covered individuals and report coverage accurately. Forms must be filed with the IRS and furnished to responsible individuals (e.g., the primary taxpayer or subscriber).
- Electronic vs. Paper Filing: Electronic filing is mandatory if submitting 10 or more information returns in aggregate (unless a hardship waiver is granted via Form 8508). Paper forms must be in landscape format, flat, and unstapled.
- Record Retention: Maintain copies or data for reconstruction for at least three years.
- Corrections: Submit a new Form 1094-B with corrected Forms 1095-B marked “CORRECTED.” Furnish updated statements to recipients.
For detailed specifications, refer to IRS Publication 5165 for electronic filing via the Affordable Care Act Information Returns (AIR) system.
Deadlines and Penalties for Non-Compliance
Timely filing is crucial to avoid hefty fines. For 2025 coverage (filed in 2026):
- IRS Filing Deadlines: March 2, 2026, for paper; March 31, 2026, for electronic.
- Furnishing to Individuals: March 2, 2026 (no extensions available).
- Alternative Furnishing Method: Instead of mailing, post a clear website notice by March 3, 2025, and provide copies within 30 days of request or by January 31, 2026, whichever is later. The notice must remain accessible until October 15, 2025.
Penalties for failures include:
| Failure Type | Penalty per Return/Statement | Annual Maximum |
|---|---|---|
| Failure to file correct return | $340 | $4,098,500 (lower for small businesses ≤$5M gross receipts) |
| Failure to furnish correct statement | $340 | $4,098,500 |
| Intentional disregard | $680 (no maximum) | N/A |
Penalties may be waived for reasonable cause under IRC Section 6724. Automatic 30-day extensions for IRS filing are available via Form 8809.
What’s New in the 2025 Instructions?
The 2025 instructions emphasize the expanded alternative furnishing method, allowing providers to use website notices instead of automatic mailing for most coverage types (effective since January 31, 2024). Additionally:
- Reporting for catastrophic health plans enrolled through Marketplaces is encouraged but not required.
- Updates reference final regulations in Treasury Decisions 9660 and 9970, plus proposed rules on TIN solicitation.
- Penalty amounts have increased slightly (e.g., intentional disregard from $660 to $680).
For the latest legislative changes, visit IRS.gov/Form1094B or IRS.gov/Form1095B.
Step-by-Step Instructions for Completing the Forms
Form 1094-B (Transmittal)
- Line 1: Enter the filer’s full name.
- Line 2: Provide the 9-digit Employer Identification Number (EIN).
- Lines 3-4: Add the contact person’s name and phone number.
- Lines 5-8: Input the complete address.
- Line 9: Note the total number of Forms 1095-B attached.
Form 1095-B (Health Coverage)
- Part I (Responsible Individual): Include name, TIN (or DOB if unavailable), address, origin code (e.g., A for SHOP, B for employer-sponsored), and leave Line 9 blank for 2025.
- Part II (Employer-Sponsored Coverage): Complete only for insured plans (codes A or B); include employer name, EIN, and address.
- Part III (Coverage Provider): Enter the provider’s name, EIN, address, and phone.
- Part IV (Covered Individuals): List names, TINs (or DOBs), and coverage months (check all-year or specific months). Use continuation sheets for more than six individuals.
Truncate TINs and EINs on recipient copies for privacy. For electronic furnishing, obtain consent.
Electronic Filing and Additional Resources
Electronic submissions must follow XML schemas in Publication 5165. Waivers for electronic filing require Form 8508 filed at least 45 days before the deadline. For software and testing, see Publication 5164.
Download the official 2025 IRS Instructions for Forms 1094-B and 1095-B PDF here: https://www.irs.gov/pub/irs-pdf/i109495b.pdf.
Conclusion
Navigating IRS Instructions for Forms 1094-B and 1095-B ensures ACA compliance and supports accurate tax reporting. By following these guidelines, filers can minimize errors and penalties while fulfilling their obligations. Consult a tax professional for personalized advice, and always check IRS.gov for updates. This guide is based on the most current sources available as of February 2026.