ACA Employer Reporting Guide: Forms 1094 and 1095

ACA reporting separates an employer’s coverage offers from the coverage people actually received. Applicable large employers generally file Forms 1094-C and 1095-C; insurers and non-ALE self-insured employers generally use Forms 1094-B and 1095-B. For 2025 coverage reported in 2026, IRS filing deadlines and the optional on-request furnishing rules require separate tracking.

This article originally covered the 2014 draft forms; the following guide replaces that preliminary discussion with the published 2025 instructions for the 2026 filing season. Do not treat these dates as the deadlines for 2026 coverage reported in 2027; confirm that year’s final IRS instructions before filing.

Match the reporting duty to the employer and plan

Section 6056 reports coverage offers by applicable large employers (ALEs), generally based on an average of at least 50 full-time employees including equivalents in the prior year. Section 6055 reports enrollment in minimum essential coverage. An ALE’s fully insured plan does not eliminate its offer reporting: the insurer’s coverage report and the employer’s offer report serve different purposes.

Common-control aggregation determines ALE status, but each ALE member files under its own employer identification number (EIN). A payroll company or reporting vendor may transmit forms, but the employer must confirm the information and filing result. Review the ACA employer mandate and affordability rules before deciding which employee months belong in the offer report.

Forms, filers and deadlines for 2025 coverage

These dates and responsibilities are confirmed in the 2025 Instructions for Forms 1094-C and 1095-C and 2025 Instructions for Forms 1094-B and 1095-B. An ALE generally files a 1095-C for each employee who was full-time for any month, applying the instructions’ limited non-assessment-period rules. A self-insured ALE also reports enrolled employees who were not full-time, plus covered family members. Special nonemployee reporting options require separate review.

Distinguish furnishing relief from IRS filing

The Paperwork Burden Reduction Act permits an alternative to automatically furnishing 1095-B and 1095-C statements. Under IRS Notice 2025-15, post a clear, conspicuous and accessible website notice explaining that individuals may request a statement. For 2025 statements, the notice was due March 2, 2026, and must remain available through October 15, 2026. Include an email address, physical address and telephone number for requests.

Furnish a requested statement no later than the later of January 31, 2026, or 30 days after the request. This is not permission to stop preparing forms or filing them with the IRS. Keep evidence of the notice, request dates and delivery. If the alternative method is not used, the ordinary furnishing deadline for 2025 statements is March 2, 2026. Separate state reporting or furnishing requirements may still apply.

The Employer Reporting Improvement Act also allows prior affirmative consent to electronic statements to remain effective unless revoked in writing. Electronic delivery is not automatic consent. For Section 6055 coverage reporting, the law permits the IRS to allow name and date of birth when a taxpayer identification number cannot be collected; follow the form instructions and solicitation requirements rather than replacing every missing employee Social Security number with a birth date.

Prepare the employee-month data before transmission

1. Confirm each EIN, ALE member and funding arrangement, including any self-insured or level-funded plan.
2. Reconcile payroll, hours, eligibility, hire and termination dates with monthly offers, employee contributions, waivers and enrollment.
3. Validate Form 1095-C offer codes, contribution amounts and safe-harbor codes against the records; populate covered-person information when required.
4. Review the authoritative 1094-C totals, electronic filing setup, furnishing method and responsibility for corrections.
5. Transmit, review the IRS acceptance or error response, correct rejected or inaccurate records, and retain the final filed version.

Electronic filing generally applies when a filer has at least 10 information returns in aggregate across covered return types, not merely 10 ACA forms. A small ACA file can therefore still require electronic submission. A timely Form 8809 can generally obtain an automatic 30-day filing extension; it does not independently extend recipient furnishing. Confirm any waiver, additional extension or disaster relief against the applicable IRS instructions.

Resolve discrepancies and preserve a defensible record

Hypothetical example: a fully insured ALE assumes its carrier’s 1095-B filing covers all employer obligations. It still needs its own 1094-C and 1095-C offer reporting. Conversely, a non-ALE self-insured employer may owe B-series reporting even though it has no employer-mandate penalty exposure. Identifying the funding arrangement is therefore as important as counting employees.

Assign one owner for discrepancies between payroll and enrollment systems. Correct an inaccurate filed form through the prescribed process instead of overwriting the source record without an audit trail. If the IRS later proposes an employer payment, use the Letter 226-J response checklist to reconcile the employee listing and preserve the proper response rights.

Primary Care Insurance Solutions (PCI Solutions) offers HR compliance and benefits administration support to organize the plan and enrollment side of reporting. Coordinate tax conclusions and filing responsibilities with counsel and your reporting provider. If a deadline has already passed, address the missing or inaccurate return promptly rather than assuming furnishing relief erased the filing requirement.