ACA reporting (Forms 1094-C and 1095-C)
ACA reporting is the annual filing on Forms 1094-C and 1095-C in which an applicable large employer reports the health coverage offered to full-time employees.
- FORM
- Form 1095-C per employee, Form 1094-C transmittal
- WHO FILES
- Employers with 50+ full-time and equivalent employees
- NO FORM?
- $340 per return and per statement (2025 forms)
- WATCH FOR
- Counting full time by your own definition, not 4980H
Next due dates
- Forms 1094-C / 1095-C on paper, if you may file on paper
- Forms 1095-C furnished to employees
- Forms 1094-C / 1095-C e-filed with IRS
Paper filing is allowed only below 10 information returns in total, or with an IRS waiver; everyone else e-files.
Instead of mailing Form 1095-C, you may post a website notice by the furnishing date and send a copy on request.
Moved to the next business day when the date falls on a weekend or bank holiday. See the full compliance calendar
Form 1095-C goes to the IRS one employee at a time, and a copy goes to the employee. You can instead post a qualifying website notice and furnish the form on request. Form 1094-C is the transmittal that summarizes the filing for your organization as a whole. You generally file if you had 50 or more full-time employees, including full-time equivalentsFull-time equivalent (FTE). Full-time equivalent (FTE) is a measure that converts employees’ hours into a number of full-time employees, so several part-time employees can count as one.Click to open the term, in the prior year. Related companies under common control count together.
What’s on Form 1095-C?
Payroll alone rarely holds every fact the form requires. The employee required contribution comes from benefits administration, not the payroll register. Self-insured plans add dependent data and taxpayer identifiers, which need validating before filing. Name an authoritative source for each field: a field with two possible owners usually ends up with none.
- 01
Part I, employee and employer. Identifying details for the employee and for you as the ALE Member.
REQUIRED - 02
Line 14, offer of coverage. A code from Code Series 1 for each month.
REQUIRED - 03
Line 15, employee required contribution. Generally the employee’s monthly share of the lowest-cost self-only coverage providing minimum value, entered only with certain line 14 codes.
- 04
Line 16, safe harbor and other relief. A code from Code Series 2 for any month one applies.
- 05
Part III, covered individuals. Self-insured plans list each enrolled employee, spouse, and dependent.
Who counts as full time?
The forms use the section 4980H definition of full time, not any other definition you use. Under the monthly method, an employee averaging at least 30 hours of service a week in a calendar month is full time. Under the look-back method, an ACA measurement period is the window you use to count a variable-hour employee’s hours of service. Averaging at least 30 hours a week across it holds full-time status for the stability period that follows.
When are the forms due?
A due date that falls on a weekend or legal holiday moves to the next business day. Check the current year’s instructions, because these deadlines and the relief around them have changed repeatedly.
- 30 days after January 31Furnish Form 1095-C to each full-time employee, or post the website notice (March 2, or March 1 in a leap year).
- October 15Keep the website notice in place through this date.
- Penalty deadline: March 31File electronically (February 28 on paper); each return not filed correctly can cost $340.
What are Forms 1095-B and 1094-B?
Form 1095-B reports who had minimum essential coverage and for which months, not what an employer offered. Form 1094-B is the transmittal that goes to the IRS with the Forms 1095-B. Who files depends on who provides the coverage. If you are an applicable large employer with an insured plan, you still file Form 1095-C for each full-time employee, but you should not complete Part III for employees enrolled in that plan. For 2025 forms, the B series had the same due dates as the C series.
| COVERAGE | WHO REPORTS IT |
|---|---|
| Insured plan, any employer | The insurer, on Form 1095-B |
| Self-insured plan you sponsor, not an applicable large employer | You, on Form 1095-B |
| Self-insured plan you sponsor, applicable large employer | Generally you, on Form 1095-C Part III |
| Non-employees in your self-insured plan, applicable large employer | You, on Form 1095-B or Form 1095-C Part III |
Frequently asked
- Instructions for Forms 1094-C and 1095-C (2025)
- Notice 2025-15, Guidance Related to Health Coverage Reporting Required by Sections 6055 and 6056
- 26 U.S. Code § 6056 - Certain employers required to report on health insurance coverage
- Instructions for Forms 1094-B and 1095-B (2025)
General information, not legal or tax advice. Apply current federal and state rules with qualified guidance.