The IRS has released Publication 5164 for the 2025 filing season, providing updated guidance for electronic submission of Forms 1094 and 1095 through the AIR system.

While the publication outlines technical standards and testing procedures, most employers will continue to rely on third-party vendors for electronic reporting due to the complexity of obtaining a Transmitter Control Code (TCC), meeting formatting specifications, and completing required testing. Employers should confirm they are prepared to electronically file or have a vendor solution in place ahead of the 2025 reporting deadlines.

Resources

ACA Employer Reporting Guide

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