The e-filing rule: an employer with 10 or more information returns must file electronically.
Many small employers reach ten returns without a single 1095-C, because W-2s and 1099s count toward the total. Once you do, paper filing is not allowed unless the IRS grants a waiver.
How the electronic filing rule works.
Ten or More
If you are required to file 10 or more information returns during the year, you must file the forms electronically.
Counted in the Aggregate
The requirement applies to information returns in the aggregate across all types, not form by form.
W-2s and 1099s Count
Forms W-2 and 1099 count toward the ten, so an employer can reach the threshold before counting any 1095-C.
How employers handle the rule.
Count Everything Early
Add up W-2s, 1099s and 1095-Cs before choosing how to file, so a paper plan is not undone by the total.
Waivers
A waiver from the electronic filing requirement is available by submitting Form 8508.
Below Ten
An employer under the threshold may file on paper, though electronic filing is also allowed.
Late Penalties Still Apply
Electronic or paper, the Section 6721 tiers of $60, $130 and $340 per return apply when the return is late.
Quick answers.
Short answers. This is general information, not legal or tax advice.
Do the Counts Include Corrected Returns?
The IRS instructions describe the threshold as 10 or more returns required to be filed during the year. Ask your preparer how corrections are counted for your filing.
Who Files Electronically?
Employers over the threshold file through the IRS’s electronic systems or a vendor. We can help you with the filing.
What if We File on Paper by Mistake?
Filing on paper when electronic filing is required can be treated as a failure to file, so correct it promptly.
Where the rules and figures come from.
Each figure on this page comes from the source below. Amounts are indexed or updated over time, so confirm current figures before relying on them.
Instructions for Forms 1094-C and 1095-C
Due dates, extensions, the posted notice option, e-filing and the $100 safe harbor.
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