What Is Form 1095-C: Employer-Provided Health Insurance Offer and Coverage?

Form 1095-C, "Employer-provided Health Insurance Offer and Coverage," is an IRS form used by Applicable Large Employers (ALEs) to report information about the health insurance coverage they offer to their full-time employees. This form is part of the requirements under the Affordable Care Act (ACA) to ensure that employers are providing minimum essential coverage that is affordable and meets specific minimum value standards.

• Who Must File: ALEs, typically employers with 50 or more full-time employees or equivalents, must file Form 1095-C for each full-time employee.
• What It Reports: Form 1095-C reports details about the health coverage offered to employees, including the type of coverage, the cost of the coverage, and the months when coverage was available. It also provides information on employees' share of the monthly premium.
• Recipient Information: Employers must furnish a copy of Form 1095-C to each full-time employee, and a copy is also sent to the IRS.
• Filing Deadlines: Employers must furnish Form 1095-C to employees by Tuesday, March 3^rd, 2026, and file with the IRS by Monday, March 2^nd, 2026 (if filing on paper) or by Tuesday, March 31^st, 2026 (if filing electronically).

Failure to comply with the requirements for Form 1095-C may result in penalties.

Form 1095-C: An Overview

Form 1095-C is a critical tax form required under the Affordable Care Act (ACA). It provides an overview of the health insurance coverage offered by Applicable Large Employers (ALEs) to their full-time employees, ensuring compliance with specific ACA requirements. Here's an overview of Form 1095-C:

• Filed by ALEs: Typically filed by employers with 50 or more full-time employees or equivalents, including governmental organizations, private employers, and nonprofits.
• Purpose: To report information about the health insurance coverage offered to full-time employees, and to demonstrate compliance with the ACA's employer shared responsibility provisions.
• Information Included: Details of the offer of coverage, including the months coverage was available, the employee's share of the monthly premium, and whether the coverage met minimum value and affordability standards.
• Recipient Copies: A copy must be furnished to each full-time employee and filed with the IRS.
• Filing Deadlines: Specific deadlines apply for furnishing the form to employees and e-filing with the IRS, generally Tuesday, March 3^rd, 2026 and Tuesday, March 31^st, 2026 respectively.
• Penalties: Failure to file or incorrect filing may result in penalties, making it crucial for employers to understand the form and comply with its requirements.

Penalties for Failing to File Form 1095-C

Failure to file Form 1095-C or failure to furnish the form to employees can result in substantial penalties for Applicable Large Employers (ALEs). These penalties are as follows:

• Failure to File with the IRS: Penalties can apply for each instance of failing to file Form 1095-C with the IRS by the required deadline. The penalty may vary depending on how late the filing is and whether there was intentional disregard of the filing requirements.
• Failure to Furnish to Employees: Similar penalties apply for failing to provide Form 1095-C to full-time employees by the deadline. Penalties can be imposed for each form not furnished to an employee.
• Potential Reductions or Waivers: Penalties may be reduced or waived if the failure was due to reasonable cause and not willful neglect. Prompt corrective action, reasonable efforts to comply, and cooperation with IRS guidance can be factors in reducing penalties.
• Adjustments for Inflation: Note that the penalty amounts can be adjusted annually for inflation, and the specific amounts may vary from year to year.

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Do You Need to Send a 1094-C with the 1095-C?

When filing Form 1095-C, Applicable Large Employers (ALEs) are also required to transmit Form 1094-C, "Transmittal of Employer-provided Health Insurance Offer and Coverage Information Returns." Form 1094-C serves as a transmittal form, providing summary information about the ALE and the 1095-C forms being submitted. It includes details such as the total number of 1095-C forms filed, the employer's name, address, and Employer Identification Number (EIN), and information regarding whether the employer met certain ACA requirements. Failure to submit Form 1094-C along with Form 1095-C may result in penalties and could affect the processing of the submission.

Who Must File Form 1095‑C?

Form 1095‑C, "Employer‑Provided Health Insurance Offer and Coverage," is required only of Applicable Large Employers (ALEs). An ALE is any single employer — or group of related employers — that averaged 50 or more full‑time employees (including full‑time‑equivalent employees, or FTEs) during the preceding calendar year.

How to Determine ALE Status

1. Count full‑time employees (FTEs). A full‑time employee averages ≥ 30 hours/week or 130 hours/month.
2. Add full‑time‑equivalent employees. Total all hours worked by non‑full‑time staff for the month (cap at 120 hours per person) and divide by 120. The result is your monthly FTE count.
3. Average across the calendar year. Add the 12 monthly totals and divide by 12. If the average ≥ 50, you are an ALE — unless you meet the seasonal‑workforce exception (≤ 120 days with > 50 employees and the excess are seasonal).

Special Situations

• Aggregated ALE groups. Entities under common control (parent–subsidiary, brother–sister, or combined groups) must aggregate their employee counts. Each member files its own 1094‑C/1095‑C set, marking the "Aggregated Group" box.
• Self‑insured ALEs. Complete Parts I–III of Form 1095‑C to report both the offer of coverage (Lines 14–17) and the months of actual coverage (Part III).
• Fully insured ALEs. Complete only Parts I–II; the carrier reports coverage on Form 1095‑B.

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What Are the Deadlines for Submitting Form 1095-C?

Deadlines for submitting Form 1095-C are critical for compliance and vary based on the filing method:

• Furnishing to Employees: Employers must furnish Form 1095-C to each full-time employee by Tuesday, March 3^rd, 2026.
• Filing with the IRS (Paper): If filing on paper, the deadline to submit Form 1095-C to the IRS is Monday, March 2^nd, 2026.
• Filing with the IRS (Electronic): If filing electronically, the deadline is Tuesday, March 31^st, 2026. Note that ALEs filing 10 or more Form 1095-C must file electronically.

Failure to meet these deadlines may result in penalties. Employers may be able to request a filing extension using IRS Form 8809, "Application for Extension of Time To File Information Returns." It's important to note that any extension requests must be submitted prior to the original filing deadline.

What Is the Difference Between Form 1095-C and 1095-B?

Forms 1095-C and 1095-B are both integral to the Affordable Care Act (ACA) reporting, but they serve different functions and are used by different entities:

• Form 1095-C:
  • Filed by: Applicable Large Employers (ALEs), typically those with 50 or more full-time employees or equivalents.
  • Purpose: To report information about the health insurance coverage offered to full-time employees, as well as to demonstrate compliance with the ACA's employer shared responsibility provisions.
  • Information Included: Details of the offer of coverage, including the months coverage was available, the employee's share of the monthly premium, and whether the coverage met minimum value and affordability standards.
• Form 1095-B:
  • Filed by: Health insurance providers, such as insurance companies, and small employers that provide self-insured health coverage.
  • Purpose: To report information about individuals covered by minimum essential coverage, including employees, spouses, and dependents.
  • Information Included: Details about the covered individuals, including names, Social Security numbers or other taxpayer identification numbers, and the months they were covered.

What If an Employee Didn't Participate in the Employer's Health Plan?

If an employee did not participate in the employer's health plan, Applicable Large Employers (ALEs) must still report the offer of coverage on Form 1095-C. Specifically:

• Part II of Form 1095-C: This section is used to report information about the offer of coverage. Employers will enter a code on Line 14 to indicate the type of offer made, even if the employee declined the coverage. Line 16 may be used to enter a code that specifies the reason the employee was not enrolled, such as a waiver of coverage.
• Other Parts of the Form: Depending on the circumstances, other parts of Form 1095-C may or may not require entries related to the employee who did not participate.

What Type of Basic Information Is Required to File 1095-C?

When filing Form 1095-C, Applicable Large Employers (ALEs) must provide the following basic information:

• Employer Information:
  • Name and address of the employer.
  • Employer Identification Number (EIN).
  • Contact person's name and telephone number.
• Employee Information:
  • Name, address, and Social Security Number (SSN) or other Taxpayer Identification Number (TIN) of the full-time employee.
  • Information on the offer of coverage using the appropriate ACA codes, including months offered, and the employee's share of the monthly premium.
  • Whether the coverage met minimum value and affordability standards.
• Other Coverage Information:
  • If self-insured, information about covered individuals, including names, SSNs or TINs, and the months they were covered.
  • Any other applicable codes or information related to the specific type of coverage offered or waivers, if applicable.