Form 1094/1095-C
What is Form 1094-C?
Form 1094-C is the IRS transmittal (summary) form filed by Applicable Large Employers (ALEs). It provides employer-level ACA information and is submitted as the “cover sheet” when you file one or more Forms 1095-C.
Form 1094-C is filed with the IRS as part of your ACA reporting package. It is not furnished to employees.
Who Must File Form 1094-C?
ALE Members file Form 1094-C when submitting Forms 1095-C for the calendar year.
If you file one or more Forms 1095-C
- You must include a Form 1094-C as the transmittal.
- Only one Form 1094-C is marked as the Authoritative Transmittal.
Important note about self-insured reporting
- Even if an employee was not full-time, a self-insured ALE may still need to file Form 1095-C to report covered individuals (Part III), as applicable.
- If you are not filing any Forms 1095-C for the year, you generally would not file Form 1094-C.
Why Form 1094-C Is Important?
ACA Summary Report
Reports employer-level ACA information to the IRS
Monthly Coverage Data
Includes monthly full-time counts and coverage indicators
IRS Compliance Check
Helps the IRS verify ALE compliance under ACA rules
Authoritative Transmittal
One Form 1094-C must be marked as the authoritative filing
Main Sections of the Form
Part I
Employer information and Authoritative Transmittal
Part II
ALE status, certifications, and employee counts
Part III
Monthly information (coverage and full-time employee data)
Part IV
Other ALE members (only if part of an Aggregated ALE Group)
Electronic Filing Rule
If you are required to e-file but do not, penalties may apply unless you have an approved waiver or reasonable cause.
IRS Filing Deadlines (Calendar Year 2025)
| Filing Method | Deadline |
|---|---|
| Paper filing (1094-C + 1095-C) | March 2, 2026 |
| Electronic filing (AIR) | March 31, 2026 |
Deadlines may shift if they fall on a weekend or federal holiday.
Penalties (Important)
Penalties may apply for failure to file correct information returns and/or failure to furnish correct statements. (Form 1094-C is filed with the IRS; Form 1095-C is also furnished to individuals as required.)
| Situation (2025 tax year) | Penalty Amount |
|---|---|
| Failure to file a correct information return (IRS) |
$340 per return Max per calendar year: $4,098,500 |
| Failure to furnish a correct statement (applies to 1095-C) |
$340 per statement Max per calendar year: $4,098,500 |
| Failure to file electronically (when required, no waiver) |
$340 per return May apply unless reasonable cause is shown |
Key Points
- Penalties are generally calculated per form.
- Special rules may apply for intentional disregard.
- Amounts can change each year based on IRS updates.
What is Form 1095-C?
Form 1095-C is an IRS information return used by Applicable Large Employers (ALEs) to report health coverage offers made to employees under the Affordable Care Act (ACA). It helps the IRS check employer compliance and helps employees understand their coverage status.
Employer-sponsored health coverage may include medical, dental, and vision plans (as applicable).
- One form for each full-time employee (as applicable)
- Shows whether health coverage was offered
- Includes coverage details for self-insured plans (Part III)
- Must be furnished to individuals as required
Form 1095-C must be filed with Form 1094-C. It cannot be filed by itself.
Who Receives Form 1095-C?
Employers must provide Form 1095-C to:
- Any employee who was full-time for at least one month of the year
- Individuals enrolled in a self-insured plan (as applicable)
- Employees who worked part of the year and later left the company (if full-time for any month)
Not required for:
- Employees who were never full-time (unless they must receive a statement due to self-insured enrollment)
- Independent contractors (unless treated as covered individuals under a self-insured plan, as applicable)
Why Form 1095-C Is Important?
Proof of Coverage Offered
Shows whether an employer offered coverage
ACA Enforcement Support
Helps the IRS enforce ACA requirements
Tax Credit Eligibility
Helps determine eligibility for premium tax credits
Compliance Requirement
Required reporting for ALE members
Main Sections of the Form
Part I
Employee and employer information
Part II
Details about health coverage offers
Part III
Covered individuals (self-insured plans only)
Filing with the IRS
IRS Filing Deadlines (Calendar Year 2025)
| Filing Method | Deadline |
|---|---|
| Paper filing (1094-C + 1095-C) | March 2, 2026 |
| Electronic filing (AIR) | March 31, 2026 |
Deadlines may shift if they fall on a weekend or federal holiday.
Furnishing Form 1095-C to Employees
| Action | Deadline |
|---|---|
| Furnish Form 1095-C (2025 tax year) | March 2, 2026 |
For 2025 forms, the furnishing due date is automatically extended from January 31, 2026 to March 2, 2026. No additional furnishing extensions are granted.
Penalties (Important)
Penalties may apply for failure to file correct information returns and/or failure to furnish correct statements. Penalties are generally calculated per form.
| Situation (2025 tax year) | Penalty Amount |
|---|---|
| Failure to file a correct information return |
$340 per return
Max per calendar year: $4,098,500
|
| Failure to furnish a correct statement |
$340 per statement
Max per calendar year: $4,098,500
|
| Failure to file electronically (when required, no waiver) |
$340 per return
May apply unless reasonable cause is shown
|
Key Points
- Penalties may be waived if the failure was due to reasonable cause.
- Special rules apply if there is intentional disregard.
- Amounts may change annually based on IRS updates.