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

10+ Returns (Aggregate)

e-filing is required if you file 10 or more information returns in total

May Apply Even With Fewer 1095-C

You may file fewer than 10 of these forms but still be required to e-file based on other returns

IRS AIR System

Electronic filing is done through the IRS AIR system

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

Filed Together

Form 1095-C must be filed with Form 1094-C

10+ Returns (Aggregate)

If you must file 10 or more information returns in aggregate, electronic filing is required.

IRS AIR System

Electronic filing is done through the IRS AIR system

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.

Frequently Asked Questions

Form 1094-C is the transmittal submitted when filing one or more Forms 1095-C. If you are not filing any Forms 1095-C for the year, you generally would not file Form 1094-C.

You must file Form 1095-C for each full-time employee (as applicable) and submit Form 1094-C with them.

If Forms 1095-C are required for the year, you must still file them and submit Form 1094-C, even if coverage was not offered.

At least one per ALE Member. Only one Form 1094-C is marked as the Authoritative Transmittal.

It is the main Form 1094-C that contains the complete employer-level summary information and represents the official filing for the ALE Member.

Yes, if they were full-time for at least one month.

No. Form 1095-C must be filed together with Form 1094-C.

Yes. If you are an ALE member and had full-time employees, Form 1095-C reporting is still required.

Yes. ALE members still file Form 1095-C. Part III is completed only if the plan is self-insured.

Yes. It must be furnished to individuals as required, by the furnishing deadline.