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Forms 1094-C and 1095-C reporting
Every applicable large employer must file Form 1095-C for each employee who was full-time for any month of the calendar year, and transmit them to the IRS with Form 1094-C. Form 1095-C reports the offer of coverage made to an individual employee; Form 1094-C is the transmittal that reports employer-level data.
Reporting is not optional once you are an ALE, and it is where the offer you believe you made becomes the offer the IRS can see.
Key takeaways
- 1095-C is per employee. One for each employee who was full-time for any month of the calendar year.
- 1094-C is the transmittal. It reports aggregate employer-level data and transmits the 1095-C forms.
- Electronic filing at 10 returns. Required if you file 10 or more information returns in aggregate across all return types during the calendar year.
- An alternative furnishing method exists. A website notice offering statements on request, furnished within 30 days of the request.
- The codes are the audit trail. Indicator codes describing your offer are what drive an IRS inquiry or a Letter 226-J.
What are Forms 1094-C and 1095-C?
They are the ACA information returns applicable large employers file each year. Together they tell the IRS what coverage was offered, to whom, and in which months — the data the IRS uses to decide whether an employer shared responsibility payment is owed.
What does Form 1095-C report?
Form 1095-C reports the offer of coverage made to an individual employee, month by month, using indicator codes. An ALE member must file a Form 1095-C for each employee who was a full-time employee for any month of the calendar year. Self-insured employers additionally report enrolled individuals, including dependents, in Part III.
What does Form 1094-C report?
Form 1094-C is the transmittal. It reports aggregate employer-level information for the ALE member and transmits the Forms 1095-C to the IRS. Where an employer is part of an aggregated group, each ALE member files its own.
Why reporting is where exposure becomes visible
- Identify every employee who was full-time for at least one month of the calendar year.
- Determine the correct offer-of-coverage and safe-harbor indicator codes for each month for each of those employees.
- If self-insured, complete Part III covering enrolled individuals including dependents.
- Furnish Form 1095-C to employees, or use the alternative website-notice method if you rely on it.
- Transmit to the IRS with Form 1094-C, electronically if you file 10 or more information returns in aggregate.
- Retain the workpapers that support each code — they are the defence to a proposed assessment.
Authoritative references
Authorities used for current calculations
- Instructions for Forms 1094-C and 1095-C — Internal Revenue Service (plan year 2025 reporting year)Supports: Who must file, the furnishing and electronic filing deadlines, the alternative manner of furnishing, and the 10-return electronic filing thresholdVerified 26 July 2026
Statutes and regulations
- Internal Revenue Code § 6056, § 6056 — U.S. CodeSupports: The statutory obligation for applicable large employers to report offers of coverageVerified 26 July 2026
Explanatory guidance
- Questions and Answers on Employer Shared Responsibility Provisions — Internal Revenue ServiceSupports: How reported offers relate to the section 4980H paymentsVerified 26 July 2026
Published 26 July 2026. Last reviewed 26 July 2026. Next review on publication of the IRS instructions for the following reporting year. 4J Insurance is an independent commercial insurance brokerage, powered by PGI, based in Frisco, Texas. This page provides general information about ACA information reporting. It is not legal advice, tax advice, actuarial advice, or an individualized compliance determination, and it is not a substitute for the instructions applicable to your filing year.
What gets filed, and when
Deadlines for the 2025 reporting year
These are the dates published in the IRS instructions for the 2025 reporting year, filed in 2026.
- Furnishing Form 1095-C to employees: by 2 March 2026
- Filing with the IRS electronically: by 31 March 2026
- Electronic filing required where 10 or more information returns are filed in aggregate across all return types during the calendar year
Deadlines are set for each reporting year in that year’s instructions. Confirm the dates before you file rather than carrying last year’s calendar forward.
The alternative manner of furnishing
Rather than mailing a statement to every employee, an employer may post a clear and conspicuous notice on its website stating that individuals may request a Form 1095-C, and then furnish the statement within 30 days of the request. The notice itself must be posted by the earlier deadline. This is a genuine administrative saving for large workforces, but it depends on the notice being posted correctly and on time.
Why the indicator codes matter more than the forms
The offer-of-coverage and safe-harbor codes on Part II of Form 1095-C are what the IRS reads. They state, for each month, whether an offer was made, to whom it extended, whether it provided minimum value, and which affordability safe harbor the employer relies on. A proposed assessment under Letter 226-J is generated from those codes and from employees who claimed a premium tax credit.
An employer whose codes describe a better offer than it actually made has created a documentation problem. An employer whose codes understate a compliant offer has invited an assessment it does not owe. Both are common, and both are fixed before filing rather than after.
Where reporting goes wrong
- Filing only for enrolled employees rather than for every employee who was full-time in any month
- Using a single code for the whole year when the offer changed mid-year
- Claiming an affordability safe harbor that was never documented
- Fully insured employers completing Part III, or self-insured employers omitting it
- Filing on paper while over the 10-return aggregate threshold
- Relying on the alternative furnishing method without posting the required notice on time
- Aggregated groups filing one return for the whole group instead of one per ALE member
What to do next
- Reconcile your full-time employee list against your 1095-C population before the filing season starts
- Confirm which affordability safe harbor you rely on and that it is documented month by month
- Check the current year’s instructions for the exact deadlines rather than assuming
- If you receive a Letter 226-J, respond within the stated window — the codes and workpapers are the response
Related resources
Continue learning
- What is an applicable large employer?
- Minimum essential coverage vs minimum value
- Monthly vs look-back measurement methods
- ACA affordability and the safe harbors
Use a tool
Check your ALE status — reporting obligations begin the year after you cross the threshold
Discuss the issue
Request an ACA compliance review — we reconcile your full-time population against the codes you filed
ACA reporting FAQ
Who has to file Forms 1094-C and 1095-C?
Every applicable large employer member. The instructions state that an ALE member must file one or more Forms 1094-C and must file a Form 1095-C for each employee who was a full-time employee of the ALE member for any month of the calendar year. In an aggregated group, each member files its own returns.
What is the difference between Form 1094-C and Form 1095-C?
Form 1095-C reports the offer of coverage made to an individual employee, month by month, and for self-insured employers also reports enrolled individuals. Form 1094-C is the transmittal that reports aggregate employer-level data and transmits the 1095-C forms to the IRS.
When is electronic filing required?
Electronic filing is mandatory if you file 10 or more information returns during the calendar year. The threshold is an aggregate across all information return types, not just ACA forms, so employers well under 10 Forms 1095-C are frequently still required to file electronically.
Can an employer avoid mailing 1095-C statements to every employee?
There is an alternative manner of furnishing. An employer may post a clear and conspicuous notice on its website stating that individuals may request their statement, and then furnish it within 30 days of the request. The notice must be posted by the applicable deadline, and failing to post it correctly removes the relief.
Do fully insured employers complete Part III of Form 1095-C?
No. Part III covers enrolled individuals and is completed by self-insured employers. For fully insured coverage the carrier reports enrollment separately, and a fully insured employer completing Part III is a common filing error.
What is a Letter 226-J?
It is the IRS notice proposing an employer shared responsibility payment. It is generated from the indicator codes reported on Forms 1095-C combined with employees who received a premium tax credit. Responding within the stated window, using the codes and the workpapers behind them, is how a proposed assessment is contested.
The codes are the offer, as far as the IRS is concerned
Reconciling them against what you actually offered is cheaper before filing than after a proposed assessment.