IRS Form 1094-B – IRS Forms, Instructions, Pubs 2026

IRS Form 1094-B – IRS Forms, Instructions, Pubs 2026 – If you’re a health insurance provider, small employer with a self-insured plan, or government entity offering minimum essential coverage (MEC), understanding IRS Form 1094-B is essential for Affordable Care Act (ACA) compliance. This transmittal form accompanies batches of Form 1095-B when reporting health coverage to the IRS.

With the 2025 tax year filing deadline approaching in early 2026, this comprehensive guide covers everything: who must file, deadlines, step-by-step instructions, penalties, and recent changes. All information comes directly from official IRS sources, including the 2025 Form 1094-B and Instructions for Forms 1094-B and 1095-B.

What Is IRS Form 1094-B?

Form 1094-B, officially titled Transmittal of Health Coverage Information Returns, serves as a cover sheet for Form 1095-B returns. It summarizes the total number of 1095-B forms submitted in a batch to the IRS.

Form 1095-B details individuals who had minimum essential coverage during the year (e.g., employer-sponsored plans, individual market insurance, or government programs like Medicaid). This reporting falls under Internal Revenue Code Section 6055 and helps the IRS verify compliance with the individual shared responsibility provisions (though the penalty for lacking coverage ended after 2018).

In short:

  • Form 1094-B = The “summary transmittal” for the IRS.
  • Form 1095-B = The detailed “individual coverage statement.”

You cannot file 1095-B forms without a corresponding 1094-B.

Who Must File Form 1094-B?

Entities providing minimum essential coverage must report under Section 6055. Use Form 1094-B (with 1095-B) if you are:

  • Health insurance issuers and carriers — For most insured plans (individual market, fully insured employer-sponsored, SHOP coverage).
  • Small employers (fewer than 50 full-time employees) — Sponsoring self-insured health plans (not subject to employer shared responsibility provisions).
  • Government entities — Reporting coverage under programs like Medicare Part A, TRICARE, VA health care, or CHIP (with some exceptions).
  • Other providers — Such as multiemployer plans, associations, or sponsors of designated MEC (e.g., refugee medical assistance).

Important exception: Applicable Large Employers (ALEs, 50+ full-time employees) with self-insured plans use Form 1094-C and 1095-C instead. ALEs may use 1094-B/1095-B only for nonemployee coverage in limited cases.

Form 1094-B vs. Form 1094-C: Key Differences

Aspect Form 1094-B Form 1094-C
Primary Users Insurers, small self-insured employers, government programs Applicable Large Employers (ALEs)
Purpose Transmits 1095-B (individual coverage details) Transmits 1095-C (offer and coverage details)
Key Reporting Minimum essential coverage only Employer offers, affordability, and coverage
Common For Fully insured plans, small self-funded plans Large employer-sponsored plans

If you’re unsure which form to use, check your status as an ALE and plan type on IRS.gov.

2026 Deadlines for Form 1094-B (2025 Coverage Year)

Filing with the IRS:

  • Paper: March 2, 2026
  • Electronic: March 31, 2026

Furnishing to Individuals (Form 1095-B):

  • Original deadline: March 2, 2026.
  • New alternative method (per 2025 instructions): No automatic mailing required. Post a clear, conspicuous notice on your public website by March 3, 2025 (keep it until at least October 15, 2026) with instructions for requesting a copy. Provide the form within 30 days of a request (or by January 31, 2026, whichever is later). New Jersey residents still require proactive furnishing.

Electronic filing is mandatory if you file 10 or more information returns (across all types) in the calendar year. Use the ACA Information Returns (AIR) system.

Extension: Request via Form 8809 (automatic 30 days; additional for hardship).

Step-by-Step: How to Complete Form 1094-B

Form 1094-B is short and straightforward. Download the official 2025 PDF here: https://www.irs.gov/pub/irs-pdf/f1094b.pdf.

Line-by-Line Instructions:

  1. Filer’s Name — Legal name of the entity filing.
  2. Employer Identification Number (EIN) — 9-digit EIN (apply at IRS.gov if needed).
    3–4. Contact Person — Name and phone number for IRS questions.
    5–8. Address — Complete mailing address (use P.O. Box if applicable).
  3. Total Number of Forms 1095-B — Count of attached 1095-B returns (do not include continuation sheets).

Sign and date under penalties of perjury. Keep a copy for your records (retain data for at least 3 years).

For full 1095-B details (e.g., Part IV covered individuals), see the instructions PDF: https://www.irs.gov/pub/irs-pdf/i109495b.pdf.

How to File Form 1094-B?

Electronic (Recommended):

  • Register for a Transmitter Control Code (TCC) via the IRS FIRE or AIR system.
  • Use approved software or a third-party provider (e.g., TaxBandits, Tax2efile).
  • Transmit XML files per IRS Publication 5165.

Paper:
Mail to the IRS center based on your location (from 2025 instructions):

  • Most states (e.g., CA, NY, TX): Department of the Treasury, Internal Revenue Service Center, Austin, TX 73301.
  • Other states (e.g., IL, MO): Department of the Treasury, Internal Revenue Service Center, P.O. Box 219256, Kansas City, MO 64121-9256.
  • International: Austin, TX address.

Include Form 1094-B on top of the 1095-B stack. Do not staple or fold.

Penalties for Non-Compliance

The IRS takes ACA reporting seriously:

  • Failure to file or furnish: $340 per form (for 2025 returns), up to $4,098,500 maximum per year.
  • Intentional disregard: $680 per form, no maximum.
  • Failure to e-file when required: Additional $340 per return.

Small businesses (average gross receipts ≤ $5 million) may qualify for reduced penalties. Reasonable cause waivers are available—document your efforts.

Recent Changes for 2025/2026 Filing

  • Expanded alternative furnishing → Easier compliance—no more mandatory annual mailings.
  • Catastrophic plans → Encouraged (but not required) reporting for Marketplace catastrophic coverage.
  • Penalty inflation adjustments → Higher amounts reflect 2025 updates.

Always check IRS.gov/Form1094B for the latest developments.

Final Tips for Smooth Filing

  • Start early — Gather data from your systems or TPA.
  • Double-check EINs and addresses — Mismatches cause rejections.
  • Use e-filing — Faster, more accurate, and required for most filers.
  • Consult a professional — Tax advisors or ACA specialists can handle complex plans.
  • Download official forms — Never use outdated versions.

Official Resources:

Stay compliant and avoid penalties—proper 1094-B filing protects your organization and your covered individuals. For personalized advice, contact a tax professional or the IRS directly.

Last updated: February 2026. Information based on current IRS guidance.