The Paperwork Burden Reduction Act (PBRA) provides employers with the flexibility to distribute Forms 1095-C in a variety of ways. While this act was designed to simplify procedures for employers, the reality might be more convoluted than initially predicted. The recently unveiled guidelines for electronic delivery and on-demand furnishing options may actually increase the workload for some employers.
The creation of Forms 1095-C remains a constant requirement, meaning that the monitoring of ACA hours and mandatory employer reporting remain unchanged. And, if employers opt for an alternative delivery method, a set of additional compliance prerequisites must be met.
To opt into the alternative delivery method, employers need to provide clear notice on their public website, informing all potential recipients of Forms 1095-C about the change in delivery methods. This notice must be available from March 2nd through October 31st, 2026, for the 2025 reporting. Additionally, employers planning electronic delivery must be prepared to demonstrate compliance with the law’s electronic delivery requirements, requiring collecting and archiving employee consents to electronic delivery. For individuals who do not opt-in to electronic delivery of Form 1095-C, employers must be prepared to mail paper forms within 30 days of an employee’s request.
It’s important to understand the interaction between on-demand and electronic delivery methods. Vendors and providers often use the term “on-demand” to mean provision of a form, either physically printed and mailed or distributed electronically, while electronic delivery requires explicit employee consent to receive Form 1095-C electronically whether that is via website, link, or email.
At first glance, the Paperwork Reduction Act might seem to simplify the process of ACA compliance. In reality, it requires more steps than before. For businesses with cutting-edge technology systems and a well-equipped HR department, these changes may look manageable. However, businesses with limited resources face added work and complexity.
Furthermore, IRS guidelines require employers using the “on demand” option to be prepared to provide a paper copy of Form 1095-C within 30 days upon request to any employee who has not affirmatively opted in to electronic delivery. This means employers need to maintain a system for printing and mailing these forms, regardless of whether they adopt the new on demand delivery option.
While the Paperwork Burden Reduction Act offers more flexibility for employers in distributing Forms 1095-C, the new guidelines may create more work. As a result, traditional printing methods are still the most practical option for many businesses in 2025. It’s crucial for each business to evaluate its own capabilities and resources to decide the most suitable approach.
Questions to ask yourself:
1. Do you have a system in place for collecting and archiving electronic delivery consents from your employees?
2. How equipped is your HR department for handling changes to ACA compliance procedures?
3. Have you considered the potential increased workload that could result from the new electronic delivery requirements and on-demand options?
4. How prepared is your business to provide a paper copy of Form 1095-C within 30 days upon request if not all employees consent to electronic delivery?
5. Given your current resources and capabilities, do you think adopting the new on demand method would be more efficient, or would sticking to traditional printing methods be more practical?
6. How often do you communicate changes in procedures to your employees, and how would you plan to inform them about the changes in delivery methods for Forms 1095-C?
This blog is up to date as of May 2025 and has not been updated for changes in the law, administration or current events.
