IRS Form 1095 Bulletin Adds ACA Filing Checks 

The Internal Revenue Service has released updated technical guidance for Affordable Care Act information reporting through its tax year 2025 AIR release memo, XML schemas, business rules, and Publication 5165. The update affects the electronic filing procedures for Forms 1095-C and 1095-B and outlines how employers, insurers, and transmitters should prepare, validate, and correct ACA reporting submissions for the current filing cycle.

AIR System Update Adds New Form 1095 Filing Checks

The IRS Form 1095 technical bulletin focuses on the Affordable Care Act Information Returns (AIR) system used to electronically transmit Forms 1094-B, 1095-B, 1094-C, and 1095-C. According to the IRS release memo, schema version 1.0 and business rules version 1.0 for tax year 2025 are now active.

Federal officials said there are no major business-rule changes from tax year 2024, signaling that the government is maintaining the current ACA information reporting framework while continuing to standardize electronic filing requirements. Publication 5165 explains the technical filing structure, including XML schemas, transmission formats, acknowledgment files, unique transmission identifiers, and correction procedures.

The agency also outlined how filing systems should handle rejected submissions, TIN and name mismatches, and accepted-with-error results. Even minor formatting issues can trigger rejected filings, correction cycles, or additional taxpayer notices related to ACA compliance reporting.

Employers Continue Reviewing Form 1095-C Reporting Rules

Applicable large employers remain among the groups most affected by the updated guidance because Form 1095-C reporting still requires detailed coding for employer-sponsored health coverage offers.

The IRS instructions for Forms 1094-C and 1095-C continue to require careful reporting of affordability data, monthly employee counts, limited non-assessment periods, and the offer-of-coverage codes entered on lines 14, 15, and 16. Incorrect affordability reporting or coding errors may expose employers to employer-shared responsibility payments under Internal Revenue Code Section 4980H.

Health insurance issuers and self-insured plan sponsors filing Form 1095-B also remain subject to month-by-month minimum essential coverage reporting requirements. The bulletin encourages reporting entities to promptly submit corrections after identifying filing errors or mismatches in taxpayer data.

Form 1095-A Still Follows Separate Marketplace Reporting Rules

The updated technical guidance mainly targets Forms 1095-B and 1095-C, but the broader Form 1095 framework also includes Form 1095-A, which Health Insurance Marketplaces use to report premium tax credit information.

Form 1095-A helps taxpayers reconcile advance premium tax credit payments on Form 8962 when filing federal tax returns. Incorrect Marketplace information may create problems for taxpayers attempting to calculate premium tax credit eligibility or complete reconciliation requirements accurately during tax season.

The Affordable Care Act established different reporting tracks under Sections 6055, 6056, and 36B of the Internal Revenue Code. Form 1095-B generally verifies minimum essential coverage, while Form 1095-C documents employer health coverage offers tied to ACA information reporting obligations.

Publication 5165 Explains AIR Correction Procedures

Publication 5165 provides detailed instructions for transmitters, payroll vendors, and ACA compliance systems handling electronic submissions through the AIR platform. The publication covers XML validation standards, acknowledgment files, unique transmission IDs, and correction workflows tied to electronic filing errors.

The publication also explains how reporting entities should respond when the AIR system flags rejected submissions, accepted-with-error results, or TIN and name mismatches connected to Form 1095-C or Form 1095-B filings.

Reporting Entities Prepare for 2025 ACA Filing Season

The updated IRS technical bulletin arrives as payroll vendors, tax software companies, insurers, and benefits administrators continue preparing systems for the 2025 ACA filing cycle.

Many organizations are reviewing line-code logic, substitute statement formatting, employee coverage calculations, and electronic transmission systems to ensure they align with current AIR specifications before filing deadlines. Reporting entities may also need to determine whether previously issued employee statements require corrections or revisions before electronic filing begins.

Tax professionals and ACA compliance specialists continue advising employers and insurers to monitor IRS.gov for additional schema revisions, technical corrections, or updated instructions connected to Form 1095 reporting requirements.

Sources

• IRS Publication 5165
• Instructions for Forms 1094-C and 1095-C
• Instructions for Forms 1094-B and 1095-B

‍By William Mc Lee, Editor-in-Chief & Tax Expert—Get Tax Relief Now