IRS Form 4423 – The Affordable Care Act (ACA) requires certain entities to report health insurance coverage information to the IRS using specific forms. For organizations without an Employer Identification Number (EIN) or foreign filers, IRS Form 4423 serves as the key application to obtain authorization for electronic filing of these returns. This form is essential for complying with ACA reporting mandates, particularly for electronic submissions through the ACA Information Returns (AIR) system. In this guide, we’ll cover everything you need to know about Form 4423, including its purpose, who should file it, step-by-step instructions, and submission details. Whether you’re a foreign entity or a new filer, understanding this form can help ensure timely and accurate ACA compliance.
What Is IRS Form 4423 and Its Purpose?
IRS Form 4423, titled “Application for Filing Affordable Care Act (ACA) Information Returns,” is used to request a Transmitter Control Code (TCC) for electronically filing ACA-related information returns. The TCC is a unique identifier required to submit data through the IRS’s AIR system, which handles electronic filings for health coverage reporting.
The primary purpose of Form 4423 is to authorize the electronic filing of:
- Form 1094-B (Transmittal of Health Coverage Information Returns) and Form 1095-B (Health Coverage)
- Form 1094-C (Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns) and Form 1095-C (Employer-Provided Health Insurance Offer and Coverage)
This form is particularly relevant for entities that do not have an EIN, such as foreign filers, or those needing to update an existing application. Under the ACA, insurance providers, self-insured employers, and applicable large employers (ALEs) must report coverage details to verify compliance with minimum essential coverage requirements. Electronic filing is mandatory if you have 10 or more returns to submit.
The form was last revised in March 2016, and as of 2026, it remains the standard for these applications. It’s a three-page document available for download in PDF format from the official IRS website.
Who Needs to File IRS Form 4423?
Not every ACA filer needs Form 4423. It’s specifically for:
- Foreign filers: Non-U.S. entities, such as nonresident aliens, foreign corporations, partnerships, trusts, or estates, that lack a U.S. Taxpayer Identification Number (TIN) or EIN but are required to report ACA information.
- Entities without an EIN: Organizations that cannot apply for a TCC through the standard IRS e-Services portal because they don’t have an EIN.
- Existing applicants needing updates: If you’re revising details like contact information, roles, or adding new forms to file (without changing the EIN), use this form.
If your organization has an EIN, you should apply for a TCC directly through the IRS e-Services portal instead of using Form 4423. Common users include insurance issuers, carriers, self-insured employers, government agencies, and third-party transmitters or software developers handling ACA filings for others.
Applicable large employers (ALEs) with 50 or more full-time employees must generally file Forms 1094-C and 1095-C, while smaller providers or insurers use Forms 1094-B and 1095-B. If you’re unsure about your filing obligations, consult IRS Publication 5165 for detailed guidance on electronic ACA filings.
Key Requirements for Filing ACA Information Returns
Before applying via Form 4423, ensure you meet ACA electronic filing thresholds:
- Mandatory e-filing: Required for 10 or more information returns (reduced from 250 in prior years).
- Deadlines: For 2025 tax year returns (filed in 2026), paper filings to the IRS are due March 2, 2026, and electronic filings by March 31, 2026. Furnish copies to employees by March 2, 2026.
- TCC application timeline: Submit Form 4423 at least 45 days before the return due date to allow processing time.
Once approved, you’ll receive a TCC to use in the AIR system, which supports two transmission methods: Application-to-Application (A2A) for automated XML submissions or the user interface for manual uploads.
Step-by-Step Guide: How to Fill Out IRS Form 4423?
Form 4423 requires detailed information about your organization, responsible officials, and filing intentions. Type or print clearly, and use attachments for additional entries if needed. Here’s a breakdown:
- Application Type (Block 1): Check “New application” for first-time requests or “Revised application” for updates.
- Foreign Filer (Block 2): Indicate yes if you’re a non-U.S. entity.
- EIN (Block 3): Enter your EIN if available; leave blank for foreign filers without one.
- Business Establishment Date (Block 4): Provide in YYYYMM format.
- Transmitter/Payer Information (Block 5): Include legal name, DBA (if applicable), phone, business type (e.g., corporation, partnership), and mailing/business addresses.
- Responsible Official (Block 6): List 1-2 individuals (age 21+) with authority over filings. Include name, title, SSN/ITIN, DOB, email, phone, and citizenship status.
- Contact Information (Block 7): Provide details for 1-10 contacts for IRS communications.
- Forms Applying For (Block 8): Select 1094/1095-B and/or 1094/1095-C.
- Role (Block 9): Check transmitter, software developer, and/or payer.
- Transmission Method (Block 10): Choose A2A and/or the web-based interface.
- Signature (Block 11): A responsible official must sign and date (handwritten only).
The form takes about 20 minutes to complete, per IRS estimates. Download the latest version from the IRS website: https://www.irs.gov/pub/irs-pdf/f4423.pdf.
How to Submit IRS Form 4423 and What to Expect?
Submit the completed form via:
- Mail: Internal Revenue Service, 230 Murall Drive, Mail Stop 4360, Kearneysville, WV 25430.
- Fax: (877) 477-0572 (U.S.) or (304) 579-4105 (international).
Contact the IRS at (866) 937-4130 (U.S.) or (304) 263-8700 (international) for questions, but note that TCCs aren’t issued over phone or email. If you don’t hear back within 45 days, follow up.
After approval, use your TCC to test and submit returns through AIR. Corrections or replacements may require additional filings.
Penalties for Non-Compliance with ACA Reporting
Failing to file accurate ACA returns on time can result in penalties. For 2026 filings (2025 tax year), penalties start at $310 per return for late or incorrect submissions, with higher amounts for intentional disregard. Electronic filing via AIR helps avoid these by ensuring timely and validated submissions.
Related Resources and Tips for ACA Compliance
- IRS Publications: Review Publication 5165 for AIR technical specs and Publication 5223 for general ACA reporting guidance.
- AIR System Access: New filers must complete testing after TCC approval.
- Help for Filers: Visit the IRS ACA page for forms like 1095-B/C and instructions.
For personalized advice, consult a tax professional, especially if you’re in Lhokseumawe, Aceh, or dealing with international filings.
By properly using Form 4423, you can streamline your ACA reporting process and avoid costly errors. Stay updated with IRS announcements for any changes in 2026.