IRS Form 1094-C – IRS Forms, Instructions, Pubs 2026 – In the complex world of tax compliance, IRS Form 1094-C plays a crucial role for employers navigating the Affordable Care Act (ACA) requirements. As an Applicable Large Employer (ALE), staying informed about this form ensures you avoid penalties and maintain accurate reporting. This guide breaks down everything you need to know about Form 1094-C for the 2025 tax year, including who must file, how to complete it, deadlines, and recent updates. Whether you’re searching for “what is IRS Form 1094-C” or “how to file Form 1094-C,” we’ve got you covered with insights from official IRS sources.
What Is IRS Form 1094-C?
IRS Form 1094-C, officially titled “Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns,” serves as a cover sheet or transmittal document for submitting multiple Forms 1095-C to the IRS. It’s required under Section 6056 of the Internal Revenue Code as part of ACA reporting. This form summarizes aggregate employer-level data about health insurance offers to full-time employees and is used to determine if an employer meets the ACA’s employer shared responsibility provisions under Section 4980H.
Form 1094-C is not filed alone—it’s always accompanied by Forms 1095-C, which provide employee-specific details. For self-insured plans, it also ties into reporting under Section 6055. You can download the latest PDF version of Form 1094-C here: https://www.irs.gov/pub/irs-pdf/f1094c.pdf.
Who Must File Form 1094-C?
Not every employer needs to file Form 1094-C. It’s mandatory for Applicable Large Employers (ALEs)—those with 50 or more full-time employees (including full-time equivalents) in the previous calendar year. Each ALE member files its own Form 1094-C under its Employer Identification Number (EIN), even if part of an Aggregated ALE Group (e.g., controlled groups or affiliated service groups).
- Governmental Units: If delegating reporting to a Designated Governmental Entity (DGE), the DGE may file on behalf, but the ALE must ensure one Authoritative Transmittal reports aggregate data.
- Self-Insured Plans: ALEs sponsoring self-insured health plans report enrollment details on Form 1095-C, Part III.
- Small Employers: Those with fewer than 50 full-time employees typically use Forms 1094-B/1095-B for self-insured coverage and are exempt from 1094-C.
If you’re unsure about your ALE status, calculate your full-time employees using the monthly or look-back measurement method as outlined in IRS guidelines.
The Purpose of Form 1094-C and Related Forms
The primary purpose of Form 1094-C is to transmit Forms 1095-C and provide summary information to the IRS about your health coverage offers. This helps the IRS enforce the employer mandate, which requires ALEs to offer affordable, minimum essential coverage to at least 95% of full-time employees to avoid penalties.
Related forms include:
- Form 1095-C: Details offers of coverage to individual full-time employees.
- Forms 1094-B/1095-B: Used by non-ALEs or insurers for minimum essential coverage reporting.
Failure to file can result in penalties up to $340 per return, with maximums reaching over $4 million for large employers.
How to Complete Form 1094-C: Step-by-Step Breakdown?
Form 1094-C consists of four parts. Here’s a detailed overview based on the 2025 version:
Part I: Applicable Large Employer Member (ALE Member) Information
- Lines 1-8: Enter your name, EIN, address, and contact details.
- Lines 9-16: If using a DGE, provide their information.
- Line 18: Total number of Forms 1095-C submitted.
- Line 19: Check “Yes” if this is the Authoritative Transmittal (one per ALE; includes aggregate data in Parts II-IV).
Part II: ALE Member Information
- Line 20: Total Forms 1095-C filed on behalf of the ALE.
- Line 21: Check if part of an Aggregated ALE Group.
- Line 22: Certifications of Eligibility (e.g., A for Qualifying Offer Method, D for 98% Offer Method). The 98% Offer Method simplifies reporting by skipping full-time employee counts in Part III if coverage is offered to 98% of employees.
Part III: ALE Member Information—Monthly
This table requires monthly data:
- Column (a): Minimum Essential Coverage Offer Indicator (Yes/No if offered to 95% of full-time employees).
- Column (b): Full-Time Employee Count (exclude Limited Non-Assessment Periods).
- Column (c): Total Employee Count.
- Column (d): Aggregated Group Indicator.
- Rows cover all 12 months or “All 12 Months” if consistent.
Part IV: Other ALE Members of Aggregated ALE Group
List up to 30 other members’ names and EINs if applicable.
Sign and date under penalties of perjury. For detailed codes and methods (e.g., affordability safe harbors at 9.02% for 2025 plan years), refer to the instructions.
Filing Deadlines for Form 1094-C in 2026
For the 2025 tax year:
- Furnish Form 1095-C to Employees: By March 2, 2026 (automatic extension from January 31).
- File with IRS (Paper): February 28, 2026.
- File with IRS (Electronic): March 31, 2026.
| Deadline Type | Date |
|---|---|
| Furnish to Employees | March 2, 2026 |
| Paper Filing to IRS | February 28, 2026 |
| Electronic Filing to IRS | March 31, 2026 |
Extensions: File Form 8809 for a 30-day extension; additional for hardship.
Electronic vs. Paper Filing Requirements
Electronic filing is required if submitting 10 or more returns (aggregated across types). Use the ACA Information Returns (AIR) system. Waivers are available via Form 8508, but penalties apply for non-compliance ($340 per return).
Paper filers: Mail to the appropriate IRS center based on your location (e.g., Austin, TX for certain states).
Handling Corrections on Form 1094-C
If errors are discovered:
- For Authoritative Transmittals: File a standalone corrected Form 1094-C with the “CORRECTED” box checked.
- For Forms 1095-C: Submit corrected versions with a new transmittal.
- De minimis errors (under $100 on Line 15) may not require correction under safe harbors.
File corrections promptly to avoid penalties.
Recent Updates for 2025 Form 1094-C Filings
As of 2026, key changes include:
- Paperwork Burden Reduction Act: Employers can furnish Form 1095-C only upon request, provided a clear website notice is posted by March 2, 2026, with contact details for requests. Furnish within 30 days or by January 31, whichever is later.
- No major form changes from prior years, but updated affordability thresholds (9.02% for 2025 plan years).
- Increased penalties: Now $340 per failure.
For the latest developments, visit IRS.gov/Form1094C.
Conclusion: Stay Compliant with Form 1094-C
Mastering IRS Form 1094-C is essential for ALEs to comply with ACA mandates and avoid costly penalties. By understanding its structure, deadlines, and updates, you can streamline your 2025 reporting process. Consult the official IRS instructions or a tax professional for personalized advice. For more resources, check the IRS website or download the form PDF linked above.