26 U.S.C. § 6056
Section 6056 is the statute that requires applicable large employers to report offers of coverage to the IRS and to their full-time employees, using Forms 1094-C and 1095-C.
What it says and why it matters.
What Must Be Reported
Whether coverage was offered to full-time employees, the months covered, the employee’s share of the lowest-cost option and other data used to administer the employer mandate and premium tax credits.
Two Recipients
The IRS, through Forms 1094-C and 1095-C, and each full-time employee, who receives a statement.
How the Statement Is Furnished
The Paperwork Burden Reduction Act and IRS Notice 2025-15 allow furnishing on request when a notice is posted.
Primary source: 26 U.S.C. § 6056. General information, not legal advice.
A worked example.
A Reporting Calendar
An applicable large employer builds a calendar: status months recorded each month, a mid-January check of offers, furnishing notices posted by March 2 and electronic filing by March 31.
What the Rule Produces
Each date has an owner and a data source, so the forms are built from records created during the year, not reconstructed in March.
Four steps to apply it.
1. List the data
Status, offers and cost.
2. Set owners
Name who prepares each part.
3. Set dates
Furnishing and filing.
4. Review
Check before filing.
Where it goes wrong. Reconstructing data after the year ends.
The questions that come up next.
Who must file?
Applicable large employers, generally those with an average of 50 or more full-time employees including equivalents in the prior year.
Where does look-back status show up?
In the monthly status and offer codes on the forms.
Where are the due dates?
See the compliance calendar on this site.
Is the report separate from the plan?
It is a tax reporting requirement.
Does it apply to self-insured plans too?
Self-insured employers also report coverage for covered individuals.
Plan-specific questions belong with ERISA counsel, and we will bring them in.
Related sources and guides.
26 U.S.C. § 4980H
Section 4980H is the statute behind the ACA employer shared responsibility payments.
26 CFR § 54.4980H-1
Section 54.4980H-1 is the definitions section for the employer mandate.
The Full Look-Back Guide
Every rule, example and source behind this page, in one place.
Benefit Tax Code Sections Explained For Employers
The Internal Revenue Code sections behind benefit taxes.
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