Apr 24, 2026
What is Form 1094-C? Complete Overview
Future Developments
For the latest information about developments related to 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, and the instructions, such as legislation enacted after they were published, go to IRS.gov/Form1094C and IRS.gov/Form1095C.
What’s New
Alternative manner of furnishing statements. Employers no longer have to automatically send Form 1095-C to individuals. The requirement for furnishing the statement is met if the employer responsible for providing the statements provides clear, conspicuous, and accessible notice on its website that an individual may request a copy of their statement and the copy is timely furnished. For this purpose, the statement is timely furnished if provided to the individual no later than the later of January 31, 2026, or 30 days after the date of the request. For additional guidance, see IRS.gov/irb/2025-11_IRB#NOT-2025-15.
Additional Information
For information related to the Affordable Care Act, visit IRS.gov/ACA. For the final regulations under section 6056, Information Reporting by Applicable Large Employers on Health Insurance Coverage Offered Under Employer-Sponsored Plans, see T.D. 9661, 2014-13 I.R.B. 855, at IRS.gov/irb/2014-13_IRB#TD-9661. For the final regulations under section 6055, Information Reporting of Minimum Essential Coverage, see T.D. 9660, 2014-13 I.R.B. 842, at IRS.gov/irb/2014-13_IRB#TD-9660 and T.D. 9970, 2023-02 I.R.B. 311, at IRS.gov/irb/2023–02_IRB#TD-9970. For the final regulations under section 4980H, Shared Responsibility for Employers Regarding Health Coverage, see T.D. 9655, 2014-9 I.R.B. 541, at IRS.gov/irb/2014-09_IRB#TD-9655. For answers to frequently asked questions regarding the employer shared responsibility provisions and related information reporting requirements, visit IRS.gov.
For information related to filing Forms 1094-C and 1095-C electronically, visit IRS.gov/AIR. For FAQs specifically related to completing Forms 1094-C and 1095-C, go to IRS.gov/Affordable-Care-Act/Employers/Questions-and-Answers-about-Information-Reporting-by-Employers-on-Form-1094-C-and-Form-1095-C.
For additional guidance and proposed regulatory changes relating to section 6055, including the requirement to solicit the TIN of each covered individual for purposes of the reporting of health coverage information, see Proposed Regulations section 1.6055-1(h) and Regulations section 301.6724-1.
General Instructions for Forms 1094-C and 1095-C
See Definitions , later, for key terms used in these instructions.
Purpose of Form
Employers with 50 or more full-time employees (including full-time equivalent employees) in the previous year use Forms 1094-C and 1095-C to report the information required under sections 6055 and 6056 about offers of health coverage and enrollment in health coverage for their employees. Form 1094-C must be used to report to the IRS summary information for each Applicable Large Employer (ALE Member) (defined below) and to transmit Forms 1095-C to the IRS. Form 1095-C is used to report information about each employee to the IRS and to the employee. Forms 1094-C and 1095-C are used in determining whether an ALE Member owes a payment under the employer shared responsibility provisions under section 4980H. Form 1095-C is also used in determining the eligibility of employees for the premium tax credit.
ALE Members that offer employer-sponsored, self-insured coverage also use Form 1095-C to report information to the IRS and to employees about individuals who have minimum essential coverage under the employer plan.
Who Must File
An ALE Member must file one or more Forms 1094-C (including a Form 1094-C designated as the Authoritative Transmittal, whether or not filing multiple Forms 1094-C), and must file a Form 1095-C for each employee who was a full-time employee of the ALE Member for any month of the calendar year. Generally, the ALE Member is required to furnish a copy of the Form 1095-C (or a substitute form) to the employee.
An ALE Member is, generally, a single person or entity that is an Applicable Large Employer, or if applicable, each person or entity that is a member of an Aggregated ALE Group. An Applicable Large Employer, generally, is an employer with 50 or more full-time employees (including full-time equivalent employees) in the previous year. For purposes of determining if an employer or group of employers is an Applicable Large Employer, all ALE Members under common control (an Aggregated ALE Group) are aggregated together. If the Aggregated ALE Group, taking into account the employees of all ALE Members in the group, employed on average 50 or more full-time employees (including full-time equivalent employees) on business days during the preceding calendar year, then the Aggregated ALE Group is an Applicable Large Employer and each separate employer within the group is an ALE Member. Each ALE Member is required to file Forms 1094-C and 1095-C reporting offers of coverage to its full-time employees (even if the ALE Member has fewer than 50 full-time employees of its own).
For more information on which employers are subject to the employer shared responsibility provisions of section 4980H, see Employer in the Definitions section of these instructions. For more information on determining full-time employees, see Full-Time Employee in the Definitions section of these instructions, which includes information on the treatment of new hires and employees in Limited Non-Assessment Periods.
Tip: For purposes of reporting on Forms 1094-C and 1095-C, an employee in a Limited Non-Assessment Period is not considered a full-time employee during that period.
Reporting by Employers That Sponsor Self-Insured Health Plans
An employer that offers health coverage through a self-insured health plan must report information about each individual enrolled in such coverage. For an employer that is an ALE Member, this information must be reported on Form 1095-C, Part III, for any employee who is enrolled in coverage (and any spouse or dependent of that employee). See the option to file Form 1094-B and Form 1095-B, rather than Form 1094-C and Form 1095-C, to report coverage of certain nonemployees, below.
ALE Members that offer health coverage through an employer-sponsored, self-insured health plan must complete Form 1095-C, Parts I, II, and III, for any employee who enrolls in the health coverage, whether or not the employee is a full-time employee for any month of the calendar year.
For full-time employees enrolled in an ALE Member’s self-insured coverage, including an employee who was a full-time employee for at least 1 month of the calendar year, the ALE Member must complete Form 1095-C, Part II, according to the generally applicable instructions, and should not enter code 1G on line 14 for any month. For an employee enrolled in an ALE Member’s self-insured coverage who is not a full-time employee for any month of the calendar year (meaning that for all 12 calendar months the employee was not a full-time employee), for Form 1095-C, Part II, the ALE Member must enter code 1G on line 14 in the “All 12 Months” column or in the separate monthly boxes for all 12 calendar months, and the ALE Member need not complete Part II, lines 15 and 16.
Tip: An individual coverage HRA is a self-insured group health plan and is therefore an eligible employer-sponsored plan. An individual is ineligible for a premium tax credit (PTC) for a month if the individual is covered by an individual coverage HRA or eligible for an individual coverage HRA that is affordable.
An employer that offers employer-sponsored, self-insured health coverage but is not an ALE Member should not file Forms 1094-C and 1095-C, but should instead file Forms 1094-B and 1095-B to report information for employees who enrolled in the employer-sponsored, self-insured health coverage.
Note: If an ALE Member is offering health coverage to employees other than under a self-insured plan, such as through an insured health plan or a multiemployer health plan, the issuer of the insurance or the sponsor of the plan providing the coverage is required to furnish the information about their health coverage to any enrolled employees, and the ALE Member should not complete Form 1095-C, Part III, for those employees.
Reporting of Enrollment Information for Nonemployees: Option To Use Forms 1094-B and 1095-B
ALE Members that offer employer-sponsored, self-insured health coverage to nonemployees who enroll in the coverage may use Forms 1094-B and 1095-B, rather than Form 1095-C, Part III, to report coverage for those individuals and other family members. For this purpose, a nonemployee includes, for example, a nonemployee director, an individual who was a retired employee during the entire year, or a nonemployee COBRA beneficiary, including a former employee who terminated employment during a previous year.