1095 e-Delivery Notice (2025)

Recent updates to the law allow employers greater flexibility in how Form 1095-C may be provided to employees, reducing administrative burden.

For more details, please consult the IRS at this link: https://www.irs.gov/forms-pubs/about-form-1095-c

For your convenience, we have provided a short summary of the new requirements.

When mailing is not required

Employers are no longer required by federal law to automatically furnish or mail Form 1095-C to every employee if both of the following are true:

• The employer posts a clear, conspicuous, and accessible notice on its website stating that the form is available upon request, and
• The employer furnishes the form to any employee who requests a copy within 30 days of the request or by January 31, 2026.

When electronic delivery is allowed

Employers may furnish Form 1095-C electronically if the employee gives specific, affirmative consent to electronic delivery.

• A general consent (such as for W-2s) is not sufficient.
• If initial consent is given on paper, the employee must also confirm it electronically.
• The consent remains effective until revoked by the employee, and renewed consent is required if the employer changes its delivery systems.

Public Notice requirements

The notice to employees must include:

• Information about the right to a paper copy,
• The process for withdrawing electronic consent, and
• Instructions on how to request the form (including an email, mailing address, and phone number).

The notice must remain posted and accessible through October 15 of the year following the reporting year.

AllianceHCM's Active Policy:

Many employers on the AllianceHCM platform already distribute Form 1095-C electronically, reducing their delivery fees and administrative effort. Beginning with the 2025 reporting year, AllianceHCM has formalized this approach as our standard policy and recommendation, aligning with the new IRS flexibilities:

• Update – AllianceHCM will no longer automatically print and mail Form 1095-Cs on behalf of clients, eliminating associated delivery fees and administrative burden. This means that employers’ default delivery option in AllPay will be “Electronic (Paperless)” for all employees, unless they change it by January 15, 2026 to “Mail to Employee”.
• Availability – AllianceHCM will prepare the forms, file them with the IRS and also make them available electronically through AllPay under Tax Documents. If your employees have access to MyPay, AllianceHCM's employee self service portal, the 1095Cs will be placed in each employees profile for them.
• Employer Responsibility – Employers remain responsible for furnishing Form 1095-C to employees in compliance with IRS and state level rules. This means posting the notice mentioned above (see section "When Mailing is Not Required). Furthermore, it also requires ensuring that employees either (a) have provided valid electronic consent for electronic delivery, or (b) receive a paper copy upon request. Employers must also ensure compliance with any applicable state-specific requirements.
• Printing Option – Employers who wish to distribute printed copies may download and print the forms directly from AllPay. Forms are available under the “Tax Documents” tab in Company Setup or the “Pay History” tab for a specific employee.
• Unique Scenarios – We understand that certain clients may still require printing and shipping of Forms 1095-C due to unique business needs. If this applies to your organization, please navigate to AllPay / Configuration / Utilities / W2/1095C Delivery. From there, you will be able to select either Electronic (Paperless) Delivery or Mail options for both Active and Terminated employees. If you have any questions, please contact your Customer Service Representative.
  
  Note: If Employers do not change their status in AllPay (as described above) by January 15, 2026, AllianceHCM will be Electronically provide 1095C's by placing them (i) in the employer's Tax Documents section of AllPay (navigate to AllPay / Configuration / Company Setup / Tax Documents) and (ii) in each employees' MyPay profile, AllianceHCM's employee self service portal (if you are using that product).

Utilizing MyPay for Compliance and Distribution

AllianceHCM provides the “Need/To-Do” feature in MyPay to help you meet the IRS requirements for collecting valid consent and ensuring verifiable distribution.

1. Specific and Affirmative Consent
   A dedicated consent template is available for you to use that is specific to Form 1095-C. The employee’s click-through acceptance is logged and tracked, providing the necessary affirmative action and a clear audit trail for compliance.
   
   Note: The consent remains effective until revoked by the employee. If delivery systems change, renewed consent must be obtained.
   
2. Clear, Conspicuous, and Accessible Notice
   Posting the consent as a “Need/To-Do” item in MyPay ensures it is visible and easy to access for every employee. The notice can include all required elements: the right to a paper copy, instructions for withdrawal, and employer contact information. You may also choose to download the notice as a PDF for posting physically in any locations.
   
   Note: Employers must keep the notice posted through October 15 of the year following the reporting year.
   
3. Timely Response and Fulfillment
   MyPay records all employee responses (consent, withdrawal) and provides the necessary contact details for paper requests. This functionality helps employers fulfill all requests within the required 30-day or January 31, 2026 deadline.

STEPS TO CREATE NOTICE AND "NEED/TO-DO" ITEM FOR AFFIRMATIVE CONSENT OF ELECTRONIC DELIVERY

1. In order to create the public notice for publishing on your website, which is a requirement to not automatically furnish 1095Cs to your employees, you will navigate to AllPay / Configuration / ACA / ACA Electronic Notification.
2. From there, you'll be able to modify any information as necessary to create your notice, which you can preview with the Preview button, and then download as a PDF for posting on your website until October 15, 2026.
3. Following that, you'll be able to Setup a Need/To-Do item in your employees' MyPay profiles so that you can collect their affirmative consent of electronic distribution, should they want to receive the 1095C electronically (versus mail).

Tip #1: Many employers choose to create a notice, place it on their website, and simply wait for employees to request 1095Cs.

Tip #2: It's not common for employees to request 1095Cs as they are not required to complete their personal tax returns. Therefore, when an employee requests their 1095C, you may decided that it's preferable to simply navigate to Tax Documents within AllPay, print off their 1095C, and mail it to them within 30-days