Key takeaways
- The source of the coverage decides the form: Marketplace, employer, or a policy bought directly.
- Form 8962 is required only when the premium tax credit is claimed or advance payments were made.
- Do not wait for Form 1095-B or Form 1095-C to file, and do not attach any of the three forms.
- Keep the forms in the client file, because the IRS says it is a good idea to keep them on hand.
Which form the client should expect
Ask the client one question first: “Did you get your health insurance through the Marketplace, through an employer, or by buying a policy yourself?” The answer tells you which form to expect, and it is faster than waiting for the client to find the form.
Marketplace coverage through HealthCare.gov or a state marketplace produces Form 1095-A. The IRS says the annual deadline for the Marketplace to provide Form 1095-A is January 31. The client gets one even if the Marketplace coverage lasted only part of the year.
Employer coverage produces Form 1095-C only when the employer is an applicable large employer. The IRS instructions say an applicable large employer must furnish Form 1095-C to each of its full-time employees, so a client at a smaller employer should not expect one. A policy bought directly from an insurer produces Form 1095-B from the insurer or other coverage provider, and the IRS sets January 31 for that provider to furnish it.
A client can receive more than one form in the same year, and each one reports a single coverage source.
Form 1095-A and Form 8962
Form 8962 is the premium tax credit form. The IRS instructions for tax year 2025 say it must be filed with the return, attached to Form 1040, 1040-SR or 1040-NR, if the taxpayer claims the premium tax credit or if advance payments of the premium tax credit were paid for the taxpayer or anyone else in the tax family.
Decision rule: if the client enrolled through the Marketplace and any advance payment of the premium tax credit was made for anyone in the tax family, prepare Form 8962 and get the Form 1095-A before you finish the return. If no advance payments were made and the client does not claim the credit, there is no Form 8962 to prepare, even when the client has a Form 1095-A in hand.
The IRS says you need Form 1095-A to complete Form 8962. The SLCSP premium, meaning the second lowest cost silver plan premium, is reported in Part III, column B of the Form 1095-A. The client's Form 1095-A is the source for the reconciliation, not the client's memory of the plan price.
Failure mode: the SLCSP premium on the Form 1095-A is wrong. The IRS instructions say you must determine the correct applicable SLCSP premium yourself, and you do not have to request a corrected Form 1095-A from the Marketplace. Pull the plan documents and the enrollment confirmation, record the figure you used, and keep both with the return.
Form 1095-B and 1095-C do not hold up the return
The IRS says it is not necessary to wait for Forms 1095-B or 1095-C in order to file. If the form has not arrived, the IRS suggests using other records, such as insurance cards, explanations of benefits, or W-2s and pay statements that show health insurance deductions.
Do not attach any of the three forms to the return. The IRS says the taxpayer is not required to send the information forms or other proof of health care coverage with the return, and it should not attach them.
Tell the client in writing: “Please send the Form 1095-B or Form 1095-C when you receive it. Do not attach it to your return, and we will not hold the return for it unless you have a Form 1095-A still on order.” The last clause is the one that matters, because a pending Form 1095-A is the only form the IRS says to wait for.
Failure mode: the client holds the whole return until a Form 1095-B shows up. Set a cutoff date in the engagement file, and file on schedule if the form has not arrived by then.
What to keep, and for how long
The IRS says it is a good idea to keep these records on hand. For the firm, that means the form belongs in the client file with the return, not only in the client's inbox.
The general IRS rule is that you must keep records supporting an item of income, deduction or credit until the period of limitations for that return runs out. The IRS standard period is 3 years, and it lists other situations with longer periods. A return filed early is treated as filed on its due date for this purpose.
Save each form as received and name it with the tax year, the form and the issuer, such as “2026 Form 1095-A Marketplace.” Keep the SLCSP figure and the enrollment confirmation in the same folder.
Dates for 2026 forms and the 2025 extension
Forms issued in early 2027 report calendar year 2026 coverage and feed the 2026 returns filed in 2027. The IRS sets January 31 for the Marketplace to provide Form 1095-A and for insurers and employers to provide Forms 1095-B and 1095-C. January 31, 2027 is a Sunday, so the practical date is Monday, February 1, 2027. Check the 2026 instructions for any automatic extension of the Form 1095-C furnishing date, as there was for 2025 forms.
For calendar 2025 forms, the IRS instructions say the due date for furnishing Form 1095-C was automatically extended from January 31, 2026, to March 2, 2026. For the same year, Forms 1094-C and 1095-C were due to the IRS by March 2, 2026, or March 31, 2026, if filed electronically. Those are 2025 dates, so do not carry them into 2026 planning.
When a due date falls on a weekend or legal holiday, the IRS instructions say the due date is the following business day. Check the actual calendar before you tell a client that a form is late. If your firm files Forms 1094-C and 1095-C for an employer client, the IRS general rule is February 28 for paper filing.
Build the intake question into the organizer
Add one coverage question for each month of the year, not one yes or no question. A client who was on a Marketplace plan from January to June and on employer coverage from July on needs two forms, and a yes or no answer hides that.
Decision rule: if the answer includes the Marketplace, expect a Form 1095-A and open a Form 8962 line. If it includes an employer, ask whether the employer is large enough to furnish Form 1095-C. If it includes a policy bought directly, ask the client to request the Form 1095-B from the insurer. Record each source with one of three statuses: received, not received, or not applicable.
In Usual, each client request is a set of fields, so the Form 1095-A, Form 1095-B and Form 1095-C can each be a separate line with its own status. Reminders then go only to the lines still open, instead of a general request to send health insurance documents.
Failure modes and the fix for each
Failure mode: the client has no form and had employer coverage. The employer may not be an applicable large employer, which means no Form 1095-C is required. Confirm the coverage with the employer and the pay stubs, and keep those in the file in place of the form.
Failure mode: the client has no Form 1095-A and it is early February. The IRS says that if you expect a Form 1095-A and it does not arrive by early February, contact the Marketplace. The IRS also says that if you need a copy, you can go to HealthCare.gov or your state Marketplace website, or call your Marketplace call center. Tell the client: “Your Form 1095-A comes from the Marketplace, not from us.” Then point them to HealthCare.gov, the state Marketplace website or the Marketplace call center, so the form arrives before Form 8962 is finished.