Fix the coverage year before using a date
For tax year 2025, filed in 2026, the final C-series instructions specify March 2, 2026 for normal employee furnishing and permitted paper IRS filing, and March 31, 2026 for electronic filing. These published dates should not be rolled into another year without checking that year's final instructions.
| Required work | Published date | Employer control |
|---|---|---|
| Normal employee furnishing | March 2, 2026 | Approved statement and delivery evidence |
| Permitted paper IRS filing | March 2, 2026 | Correct filing method and packet |
| Electronic IRS filing | March 31, 2026 | Release, transmission and outcome review |
The general e-file requirement is 10 or more specified information returns in aggregate, including other applicable return types. A small 1095-C batch alone does not establish paper eligibility.
Plan the employer's furnishing method
An employer using the federal alternative manner must satisfy the notice and request requirements. For 2025, post the notice by March 2, 2026 and retain it through October 15, 2026. Provide clear, accessible statement-request instructions with the required email, physical address and telephone contact. See Notice 2025-15 and the 2025 furnishing instructions.
Requested copies are due by the later of January 31, 2026 or 30 days after the request. Give HR a queue for every request channel, a due-date calculation and delivery evidence. Keep state furnishing decisions separate.
Set cutoffs around real dependencies
Arrange the calendar around payroll history, benefits decisions, employer approval and transmitter release. Set separate owners for late source data, unresolved employee-month scenarios and final signoff. A deadline on a shared calendar is useful only when the preceding work has an accountable owner.
Fictional Pine Harbor has 140 approved employee records and six unresolved source cases at its internal cutoff. Its manager records whether each unresolved case affects the next release and schedules a decision with the relevant source owner. The six cases stay in the reporting inventory until their required work is resolved.
Use evidence to recover and close work
If a deadline was missed, identify the actual affected workstream, current agency status and outstanding employee statements. Save the original timestamps and correction history. An internal revised date cannot be represented as an IRS extension.
The IRS filing-extension instructions describe a timely Form 8809 request; an IRS filing extension does not extend furnishing. Review the applicable rules and circumstances rather than promising relief. The audit-trail guide below helps HR connect the approved population to actual delivery and outcome records.
Choose a practical guide
Use the practical guide library below for the next step. Each guide includes a worked example, a diagram and a downloadable worksheet.
Questions from reporting teams
Is normal furnishing due March 3 in every year?
No. For 2025 Forms 1095-C, the published normal federal furnishing date is March 2, 2026. Identify the reporting year before assigning its dates.
Can HR rely only on the vendor's uploaded status?
Uploaded describes a step in the vendor workflow. Request the agency outcome and the separate furnishing evidence needed to establish what actually finished.
Does Form 8809 cover employee furnishing?
No. The filing extension and the employee furnishing requirements are separate. Keep them on separate rows in the employer calendar.
Should late source cases disappear from the release report?
No. If a record is held from a particular release, record its next owner, decision and filing responsibility. Exclusion from one batch does not resolve the underlying reporting work.
Set up your employer's filing project
Create a BoomTax account to begin your organization's filing setup. Keep the reporting year, expected return volume and reviewed source records available as you prepare the project.
