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Do you need to file Form 1095-C for 2025? Or not sure if you fit the bill? Don't stress! The 1095-C filing requirements don't have to be overwhelming. In this blog, we've pulled together a simple guide so that you know exactly what to do and when.

What Is Form 1095-C?

Form 1095-C is all about telling both the IRS and each full-time employee whether the payer offered them basic health insurance called Minimum Essential Coverage (MEC). Its companion, Form 1094-C, acts like a summary cover sheet. It summarizes all the 1095-C forms sent to the IRS.

1095-C Filing Requirements

You might want to dive into filing right away, but preparation is your secret weapon. Knowing 1095-C filing requirements makes the process much less strenuous. Let’s walk you through what you need.

Who is Required to File Form 1095-C?

So, who files 1095-C? A payer must send out Form 1095-C when that payer is considered an Applicable Large Employer (ALE) under the Affordable Care Act (ACA) for the calendar year that just ended.

That means for 2025 (filing in 2026), you determine ALE status by looking at your average employee count in 2024. This is how you do it:

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Form 1095-C Due Dates

Action Due in 2026 Details
Furnish employee copies (Copy B) March 2 Paper, secure email (with consent), or website notice + on-request copy (provide within 30 days of request)
Optional 30-day IRS extension Submit by March 1 File Form 8809 by the original IRS filing due date to postpone the IRS filing deadline by 30 days (does not extend recipient furnishing)
Mail paper 1094-C/1095-C to IRS February 28 Certified Mail or private-delivery service (if the date falls on a weekend/holiday, the next business day applies)
E-file 1094-C/1095-C March 31 Required if the payer files 10+ information returns in aggregate (W-2, 1099, 1095, etc.)

How to Fill Form 1095-C?

Filing Form 1095-C is not rocket science. Here's your 1095-C filing guide to keep the IRS satisfied and skip the compliance hassles.

Header

Enter payer EIN, street address, and phone, exactly how it appears on your payroll tax returns (Forms 941/944).

Part I columns (Employee)

Verify names and SSNs carefully. ACA e-filers receive AIR acknowledgements that flag name/TIN mismatches. So, you can fix it and resend easily.

Part II monthly rows

Part III (self-insured plans only)

List everyone covered. Enter each person's SSN or, if unavailable, their full date of birth will do.

Form 1094-C cover sheet:

Tick “Authoritative Transmittal,” fill in total full-time employees by month, and certify that MEC was offered to at least 95% of them.

Note: Tax1099 imports your payroll, auto-selects the right codes, builds the IRS XML with the required manifest pairing, and validates common AIR rules before transmission.

Form 1095-C Penalties

What happens if you miss deadlines or send out forms with errors? The IRS is a stickler for rules. So, you attract avoidable ACA penalties 1095-C late. Here's what your mistakes could cost you.

Problem Likely 2026 Fine* How to Fix or Avoid
Late or incorrect form Up to ≈ $340 per return; annual caps apply File or correct within 30 days to reduce to ≈ $60; 31-August 1 ≈ $130
Intentional disregard ≈ $680 per form; no cap Show “reasonable cause” where applicable and file Form 843 to request abatement
No offer to ≥ 95% full-timers (§4980H(a)) ≈ $3,340 per full-time employee (prorated; minus first 30 employees) Offer MEC to enough staff; use affordability safe harbors; use code accurately

Where State Reporting Comes In

Some jurisdictions require state 1095-C reporting, not just the federal ACA filing.

Quick Checklist for Filing Form 1095-C

Here's a quick checklist for payers to stay on top of 1095-C filing requirements and never miss 1095-C deadlines 2026.

Real-Life Scenarios

Situation Payer’s Correct Step Outcome
55 full-time staff; $125/month plan File 1095-C for each employee; code 1A all months Meets 95% offer rule; no penalty
48 full-time + PT equivalents No 1095-C for 2025; monitor monthly counts Remains below ALE threshold
Union workers in multi-employer plan Use codes 1H (Line 14) and 2E (Line 16) per current instructions Safe-harbor relief applies (watch for changes in future years)
Employee leaves in June, elects COBRA Show offer January-June; use 2A (not employed) July–December; don’t use 2C for COBRA months after termination Form mirrors actual coverage
Remote staff in CA and NJ File with IRS and states via FTB MEC IR (CA) and NJMRT (NJ) Meets both state mandates

Frequently Asked Questions:

Yes. ALEs must still file 1095-C for each full-time employee. Just make sure to indicate that there was no offer of coverage.

Usually, no. But if the ALE is self-insured and a part-time employee enrolled in coverage, then the employer reports that coverage in Part III of their form.

This is because the IRS aggregates every W-2, 1099, and 1095 you file. If the combined hits 10 or more, Form 1095-C electronic filing is a must.

Yes! But you must obtain consent for electronic delivery. You can also use the website notice along with the on-request method if you meet the posting and response requirements.

At least for three years from the due date. Many employers go for four to align with internal policies or state rules.

No more risk of errors or penalties! With Tax1099, import data, generate Line codes automatically, and e-file your federal and state ACA forms in a single secure step.

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