ACA Forms 1094-C and 1095-C Reporting
Who has to file, the deadlines, how employee copies can be furnished, and the penalties, based on the IRS instructions for the 2025 reporting year.
Which Employers Report
These dates are from the IRS instructions for the 2025 reporting year, filed in 2026. The IRS publishes new instructions each year, so confirm dates for the reporting year you are filing.
Applicable Large Employers
An applicable large employer generally has 50 or more full-time employees, including full-time equivalents, in the prior year. Each one files Form 1094-C and Forms 1095-C. To set the filing and notice dates for a given year, try our 1095-C deadline calculator.
Each Employer Files Under Its Own EIN
Each applicable large employer member files under its own employer identification number, even inside an aggregated group. This means an employer in a controlled group cannot file one combined return for the whole group. Each member keeps its own records, so the group should coordinate on data, deadlines and who prepares the filings.
Form 1094-C
The transmittal form that summarizes the employer and accompanies the 1095-C forms filed with the IRS. The transmittal form serves as the cover for the filing, so its totals should agree with the individual statements submitted. Employers who use an outside vendor should review the summary before it is submitted.
Form 1095-C
The statement for each full-time employee showing the offer of coverage and any coverage the employee enrolled in. The statement is also what employees may use when preparing their own tax returns, so accuracy matters for them as well. Employers should check names, coverage months and offer codes for errors before the forms go out.
Self-Funded Plans
Self-insured coverage is reported on the same form. Offer codes, including code 1G for an employee enrolled in self-insured coverage who was never full-time, are in the IRS instructions. The reporting rules for self-insured coverage differ in some details, so employers should work with their administrator and a tax adviser. Keeping enrollment records clean throughout the year makes the final form easier to complete.
Smaller Employers
Employers below the large employer threshold do not file these forms. Employers with self-insured plans have separate reporting obligations. Ask us.
Dates and Penalty Amounts
Filing With the IRS
For the 2025 reporting year, Forms 1094-C and 1095-C were due by March 2, 2026, or March 31, 2026 if filed electronically. Deadlines can shift when the IRS announces extensions or when dates fall on weekends, so check the current instructions each year. Employers using an outside vendor should confirm the vendor’s internal schedule well ahead of the date.
Furnishing to Employees
Form 1095-C was due to each full-time employee by March 2, 2026. The IRS extended it automatically from January 31 and said no additional extensions would be granted. Employees may also need the form when preparing their own returns, so late delivery can cause questions. Employers should confirm the current year’s deadline in the IRS instructions, since extensions are not guaranteed from one year to the next.
Electronic Filing
If you are required to file 10 or more information returns during the year, you must file electronically. A waiver is available on Form 8508. The threshold counts across various return types, so employers should check the total with their payroll and benefits vendors. Those who fall below it may still choose to file electronically, which is generally faster to confirm.
Penalty per Return
The IRS instructions list a $340 penalty per return or statement for failure to file or furnish a correct one, with a calendar year 2025 cap of $4,098,500 for each. Amounts are adjusted for inflation and can change from year to year, so confirm the figures in the current instructions. A tax adviser can explain how they might apply to a late filing or an incorrect statement.
Higher Penalties
Higher amounts apply for intentional disregard, and penalties may be waived for reasonable cause. Reasonable cause is decided on the facts, so employers should document what happened and when. Counsel or a tax adviser can help assess whether relief is available and how to request it after an error.
The Next Cycle
Reporting for 2026 happens in early 2027. Confirm the dates when the IRS posts the 2026 instructions. Employers can use the quiet months to clean up eligibility and offer data, rather than starting from scratch in the new year. Build the calendar early and confirm any extension the IRS announces.
Posting a Notice Instead of Mailing Every Form
The Alternative Method
Employers no longer have to automatically send Form 1095-C. They can post a clear, conspicuous notice on their website that individuals may request a copy. The alternative method only works if the notice is easy to find and the employer can respond to requests on time. Employers should confirm with a tax adviser that they meet every condition before relying on it.
Posting Window
For the 2025 reporting year the notice had to be posted by March 2, 2026 and kept up through October 15, 2026. Employers using this method should keep evidence of when the notice went up and when it stayed posted. Check the current year’s IRS instructions, since dates and conditions can change from one reporting year to the next.
Responding to Requests
Requested statements must be furnished by the later of January 31, 2026 or 30 days after the request. Employers should have a simple process for logging requests and tracking the response date, whether HR or a vendor handles it. Keeping a record of when each statement went out helps if the IRS or an employee asks questions.
Qualifying Offer Method
An employer may use the qualifying offer method for employees who received a qualifying offer for all twelve months and did not enroll in self-insured coverage. The IRS instructions explain the alternative completion method and code 1A. This method can reduce the work for employers with a stable group of full-year offers, but it applies only when every condition is met. A tax adviser or the filing vendor can confirm whether it fits your workforce.
Line 14 Is Never Blank
Enter an offer code for every month, January through December. If an employee was not offered coverage for a month, enter code 1H. Leaving months blank or entering the wrong code is a frequent source of IRS notices, so a final review of the data before filing is worthwhile. Vendors and payroll teams should agree on how offer codes are assigned.
Questions Employers Ask
Do We Have to Mail Every Employee a 1095-C?
Not necessarily. The IRS allows a posted notice that employees may request a copy, with conditions. See the section above.
What Counts as Filing Electronically?
If you file 10 or more information returns of any kind in the year, you must file electronically. W-2s and 1099s count toward the ten.
What Is the Penalty?
The 2025 instructions list $340 per return or statement, with a calendar year cap of $4,098,500 for each, higher for intentional disregard.
Who Prepares the Forms?
Many employers use their payroll or benefits administration system. Ask your administrator which forms it produces and who reviews them.
Do We File if We Are Under 50 Employees?
Applicable large employers file. Smaller employers generally do not file these forms. Ask us if you are near the threshold.
Where Does Affordability Fit?
The offer codes reflect whether coverage was affordable. See our ACA affordability calculator and the compliance hub for the percentage.
What Changes Next Year?
The IRS posts new instructions every year. Check for new dates before the filing season.
Is This Tax Advice?
No. This is general information from benefits advisors. Consult your tax advisor.
Is this legal advice?
No. This page is general information, not legal advice. Rules change and facts differ, so confirm your situation with your attorney or tax advisor.
Related Guides
Related reading: ACA Affordability Calculator · Michigan Compliance Calendar · HSA, FSA and Section 125 Limits · Michigan Benefits Compliance Hub · Controlled Group Rules for ACA Employer Counts · W-2 Box 12 Code DD: Reporting the Cost of Health Coverage · Opt-Out Payments and ACA Affordability
Related guides.
Franchise and Multi-Location Operators
Planning group health across stores, entities and owners.
Variable-Hour and Seasonal Employees
How the ACA look-back measurement method works.
Send us your renewal.
We’ll tell you whether it looks competitive, where we see opportunity, and the five questions we’d put to your carrier. No cost, and no obligation to move anything.
The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier
Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.
An independent employee benefits consulting firm. We look at the entire benefits program — cost, plan performance, risk and administration.
Switch to CFH. Unhappy with your broker? Your employees won’t notice. You will. →
Cookies on This Site
We use cookies to keep the site working properly and to understand how it is used. You can decline anything that is not essential. See our Privacy Policy for the detail.
- Essential — needed for the site to load and for you to move around it. These cannot be switched off.
- Analytics — tell us which pages get read, so we know what is worth writing more of.
- Advertising — set by third parties such as ad and social platforms to measure and target campaigns.