1095-C Recipient Requests and Furnishing: A Timing Checklist

Record the ALE member, reporting year and employee population covered by the furnishing decision. The employer can use direct furnishing or, when its conditions are met, the alternative notice-and-request method. Keep this decision separate from IRS filing and any state duties.

Notice 2025-15 extends the alternative method to section 6056 full-time employee statements for calendar years after 2023. This differs from older limited relief for non-full-time employees and nonemployees enrolled in self-insured coverage. Read the final C-series instructions together with the notice so an older paragraph does not incorrectly narrow the newer method.

The notice must be clear, conspicuous and accessible, explain that the employee can request a statement, and include the required email address, physical mailing address and telephone contact. It must be posted by the statement furnishing due date, including the automatic extension, and kept available through October 15 of the filing year.

For the verified 2025 reporting cycle, the C-series instructions state March 2, 2026 for furnishing and notice posting, with availability through October 15, 2026. These dates do not establish the next year's calendar. Save publication evidence and review website changes so a redesign or employee-portal migration does not remove access for former employees.

Under Notice 2025-15, the requested statement must be furnished by the later of January 31 following the reporting year or 30 days after the request. Keep both dates and the selected later date in the request record. The rule is not simply 30 days after a staff member begins processing.

Capture the original request receipt, even when it reaches HR, a payroll provider or a general office first. Route it promptly and preserve repeat messages without resetting the date. Verify the employee and destination through the established process, but do not assume verification or internal reassignment suspends the deadline. Set earlier internal targets for retrieval and furnishing.

A fictional former employee requests a 2025 Form 1095-C on April 8, 2026. The employer's notice was timely posted and otherwise qualifies. Thirty days after the request is May 8, 2026, later than January 31, 2026. The employer chooses an internal April 20 target to allow recovery time.

The internal target is intentionally earlier. It does not replace the governing response calculation or prove that furnishing happened.

Retrieve the correct employee, ALE member and reporting-year statement. Someone who worked for more than one reporting entity may have separate forms. Do not substitute a group-wide document or the newest year's statement when the request identifies a particular employer and year.

The C-series instructions require affirmative consent specific to electronic Form 1095-C furnishing, subject to the stated exceptions. Preserve consent and the actual destination and furnishing event. A former employee may no longer have access to the payroll portal. Resolve that access problem through an appropriate furnishing route instead of repeatedly sending a link the employee cannot use.

Record statement version, actual furnishing date, method and supporting evidence. Keep unsuccessful delivery attempts and any correction request linked to the case. If the employee disputes offer or enrollment data, route the substantive decision to the reporting reviewer without deleting the original request history.

Continue notice availability and inbox coverage for the required period. Maintain a backup owner for absences and a queue sorted by response date. The notice/request method does not remove employer reporting to the IRS or necessarily satisfy state obligations. At annual review, retain evidence of both notice performance and individual responses, and reverify dates and conditions for the next reporting year.

Keep a coverage plan for requests arriving through published channels during absences. An employee may contact the public telephone number before an internal ticket exists. Preserve that first request event when routing work, and record who checked the inbox and telephone messages for outstanding items.