ACA Forms 1094-C and 1095-C

Benefits Concepts / Compliance, Documents, and Claims
ACA Reporting

ACA Forms 1094-C and 1095-C

Applicable large employers use Forms 1094-C and 1095-C to report employer coverage offers under Code Sections 6055 and 6056. Accurate reporting depends on monthly employment, eligibility, offer, affordability, enrollment, and self-funded coverage data agreeing across systems.

Reviewed July 29, 2026 · Source-led practitioner reference

Who files

An applicable large employer generally averaged at least 50 full-time employees, including full-time equivalents, in the preceding calendar year. Each ALE member has its own filing responsibility even when the controlled group is larger.

Form Role
1094-C Transmittal for the employer’s Forms 1095-C and employer-level information
1095-C Employee-level monthly report of coverage offers and related data; a self-insured ALE also reports covered individuals

2025 forms filed in 2026

  • Electronic filing with the IRS was due March 31, 2026.
  • Employers filing 10 or more information returns in the aggregate generally must file electronically.
  • Alternative furnishing may be available when the employer posts the required website notice by March 2, keeps it accessible through October 15, and provides a requested statement within 30 days.

Monthly data that drives the form

  • Full-time status and limited non-assessment periods.
  • Offer of coverage to the employee, spouse, and dependents.
  • Employee required contribution for the lowest-cost qualifying offer.
  • Applicable affordability safe harbor and other indicator codes.
  • For self-insured coverage, each covered individual and covered months.

Quality-control sequence

  1. Confirm ALE and ALE-member structure.
  2. Reconcile payroll hours, HR status, eligibility, offers, waivers, and enrollment.
  3. Validate code combinations and monthly contribution amounts.
  4. Review IRS acknowledgments and rejected records.
  5. Correct errors promptly and retain the source logic behind each field.
Do not use this year’s dates forever: ACA filing and furnishing dates move with weekends, holidays, and changing procedures. Recheck the instructions for the reporting year being filed.

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Primary sources

Educational reference only. Plan documents, governing law, agency guidance, and plan-specific professional advice control.

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