Who must file Forms 1094-C and 1095-C, and what counts as a return.
Applicable large employers, generally those that averaged at least 50 full-time employees including equivalents in the prior year, report offers of coverage every year. Each form is its own return for penalty purposes.
Which employers report.
Applicable Large Employers
Employers that averaged at least 50 full-time employees, including full-time equivalents, in the prior calendar year.
Controlled Groups
Each member of a controlled group files for its own employees.
Self-Insured Smaller Employers
An employer under 50 that self-insures reports coverage on Forms 1094-B and 1095-B.
Why the per-form math matters.
Each 1095-C Is a Return
One submission covering 100 employees is 100 returns, each with its own penalty exposure.
The 1094-C Is One Too
The Form 1094-C transmittal is an information return as well.
The Statement Penalty Doubles It
Section 6722 adds a matching penalty for each statement not furnished to the employee.
Caps Soften the Total
Annual caps apply, starting at $244,500 for smaller employers corrected within 30 days, for returns due in 2027.
Quick answers.
Short answers. This is general information, not legal or tax advice.
Is There a Size Cutoff?
The line is 50 full-time employees including equivalents for the employer mandate and its reporting, measured on the prior calendar year.
Do We File if We Offer No Coverage?
An applicable large employer files either way, because the form also reports that coverage was not offered.
Who Prepares the Forms?
Most employers use payroll and enrollment data. We can help you with the filing and help keep you ERISA compliant.
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.
IRS Employer Shared Responsibility
Letter 226-J, Letter 227 and the employer mandate overview.
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