How to File Form 1095-C? Complete 1095-C Box-by-box Filing Instructions 2025

If your company is an ALE or an Applicable Large Employer, not only do you need to offer health coverage to remain compliant with ACA requirements, you must also report it to the IRS using Form 1095-C. Form 1095-C reports what health coverage was offered, for which months, and at what cost to the IRS.

Learning how to file 1095-C is important as it helps your company stay compliant with both IRS and ACA requirements.

Understanding Why Form 1095-C is Required 

Form 1095-C details the type of health coverage offered to an employee. It is used by Applicable Large Employers (ALEs) or those with 50 or more full-time employees (including full-time equivalent employees).

The form shows the IRS that health coverage is being provided by the employer. It also determines if employees are eligible for the Premium Tax Credit and whether the coverage provided to employees is affordable or not.

Who Needs to File Form 1095-C?

As a payer, who must file 1095-C? The payer for 1095-C is the Applicable Large Employer (ALE) that must offer health insurance coverage to full-time employees under the Affordable Care Act (ACA).

But who qualifies as an ALE?
An ALE is an employer that averaged 50 or more full-time employees, including part-time hours converted to full-time equivalents (FTEs), in the previous calendar year. Note that all the controlled or related companies count together for the ALE 50 employee rule. However, each company part of the group files separately under its own EIN.

Basically, as an ALE, you must file a 1095-C for every employee who clocked full-time status for at least one month during the year. You must also furnish the copies to the employees. An employee is considered a full-time employee if they average at least 30 hours of work per week, or 130 hours in a month.

You can calculate the working hours using either: 

• Monthly measurement method: Track how many hours they worked each month. 
• Look-back measurement method: Track how many hours they worked over a past period and based on that,  decide whether they are considered full-time for a future period. 
• If you have related companies with separate EINs but share staff, you combine the employees during filing. 

What to File in 1095-C?

Form 1095-C is divided into three parts. Each part requires accurate information to remain compliant with ACA and IRS filing requirements.

Part I: ALE and employee contact information

This section of the 1095 C form requires employee’s name, address, and SSN as well as the applicable large employer’s name, address, and EIN.

Part II: Health Coverage Plan Details 

This second part of the form covers the monthly health coverage details for each full-time employee. It reports what type of health coverage was offered, the cost of the lowest-priced self-only coverage, and whether the employee was enrolled for each month of the year. 

Line 14: Reports the coverage code that applies, based on the type of coverage offered and to whom it was offered.  

Line 15: Reports the monthly cost to the employee for the lowest-cost, self-only plan that meets ACA standards. 

Line 16: Reports an applicable safe harbor code or other code under Section 4980H that explains why the employer may not be liable for a shared responsibility payment for that employee for that month. 

Part III: For self-insured plans provided by employers 

Form 1095-C Part III is required only if the employer offers self-insured health coverage. If you are not offering self-insured coverage, you can leave this part blank.  

In this section, you have to list the individuals who had coverage under the employer’s plan, including the employee and any covered family members.  Include the months in which the person had minimum essential coverage.

If you want to understand in detail, refer to our box-by-box filing instruction for 1095-C 

How to file 1095-C electronically with Tax1099?   

1) Upload data  

Import employee data from your HR or accounting systems directly into Tax1099 platform with no-code integrations. Or use API integration to seamlessly transfer data from your system to our 1095-C e-file platform.  

2) Use built-in checks  

Use TIN match to verify name and EIN/SSN combinations with IRS data. And USPS address validation to make sure the addresses provided are valid and accurate. 

3) Attach Form 1094-C 

Attach 1094-C when you e-file 1095-C. Form 1094-C provides a summary about the employer, including  EIN, number of employees, and the number of 1095-C forms being filed.

4) Click Transmit and wait for the IRS “Accepted” note.   

After inputting all the data and reviewing the information, you can e-file 1095-C form with Tax1099. You’ll receive a confirmation after transmitting the form. We also let you store tax information for up to 4 years for audit purposes.

Stay compliant and audit-ready!
Confirm ALE status, choose the right forms, run the checklist, and e-file Form 1094-C/1095-C effortlessly with Tax1099.

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Form 1095-C: Key Deadlines for 2025 TY

Tip: Mark the three dates on one calendar: internal data lock → March 2 furnish → March 31 e-file.

Remember the 10-return e-file rule. If the payer files 10 or more total information returns for the year (W-2, 1099, 1095, etc. combined), e-filing is mandatory. Also, if you need more time for IRS submission, File Form 8809 for an automatic 30-day extension.

Coverage type matters

• Self-insured ALE: Fill Part III to list covered people (employee and family).
• Fully insured ALE: Skip Part III; the insurance carrier sends Form 1095-B for coverage.

Common pitfall: Never fill in Part III for a fully insured plan. Doing so can trigger IRS rejections or penalties.

Fixes & Penalty Relief   

ALE 1095-C rules impose penalties on non-compliance with filing requirements. If you fail to file a correct information return, you will be fined $330 for each return.  

If you filed a wrong 1095-C form, you can correct it by re-filing a new form with the correct information.  

For forms already submitted to the IRS: 

If you’ve already send the form to the IRS, you can correct it by entering the correct information and checking the “CORRECTED” box before sending it to the IRS. Do not mark “CORRECTED” on Form 1094-C. 

You must also provide a copy the employee, unless you’re using the Qualifying Offer Method. In such cases, all you need to do is to file a corrected statement if the corrections involve your company’s name, EIN, address, or contact details. 

Note: If the only error is Line 15 and the difference is less than $100, you generally don’t have to correct as per safe harbor rules. 

For forms sent to employees: 

If you discovered an error after sending the copies to employees, you must send a new clearly mark “CORRECTED” form on the employee’s copy of 1095-C. 

Special Cases

There are certain situations where ACA reporting needs to be handled a bit differently. Here’s a simple guide:

• Union/multiemployer plans: Treat certain union employees as having an offer of coverage and apply the standard line codes.
• COBRA participants and retirees: If an individual is not an employee for any month, report coverage on Form 1095-B. If the same person was full-time for any month while employed, file a Form 1095-C for that year.
• Individual Coverage Health Reimbursement Arrangement (ICHRA): Report it on Form 1095-C. The affordability safe-harbor selected affects which line codes apply.
• Not an ALE but self-insured: File Forms 1094-B and 1095-B.

Mistakes to Avoid

Note these common mistakes to make sure you are compliant and avoid hefty penalties. We also have a simple pre-filing checklist for you to run your eyes over in case you’re swamped.

• Failing to file or furnish Form 1095-C for full-time employees.
• Treating multiple related companies as one filer. Remember, each entity with its own EIN must file separately.
• Filling Part III for fully insured plans.
• Forgetting the main/1094-C summary filing.
• Ignoring the 10-return e-file rule.

Fix: File CORRECTED forms and re-furnish corrected employee copies within 30 days of spotting the mistake.

1095-C Pre-filing checklist

• Collect W-9s to collect employee names, SSNs, and addresses before starting the 1095-C filing process.  
• Calculate the total number of months an employee has worked. Count all employees who were full-time as per ACA rules. 
• Add part-time employees’ hours together until they are equal to “full-time equivalents.” 
• Determine the monthly cost of the cheapest single coverage (self-only) plan. 
• Use Tax1099 real-time TIN-match to check name and SSN/TIN combos with IRS data.   

State Add-Ons

Beyond the federal ACA filings, there are some states which impose additional rules for reporting. It’s important to determine every state ACA reporting (CA, DC, NJ, RI, MA) requirements.

For example, California, New Jersey, Rhode Island mandate ACA data for residents. In most cases, it must be submitted electronically to the state’s tax department.

Another example is Massachusetts requires a separate health-coverage form—Form MA 1099-HC which uses its own health coverage form (MA 1099-HC).

Tip: For any state where employees live, confirm whether the insurance carrier files or the employer files the forms.

Real-Life Scenarios

Scenario 1: Two related companies; 30 full-time employees each, totalling 60:

• Both are ALE Members.
• Each company must file its own Form 1094-C, and all Forms 1095-C for its employees.

Scenario 2: Fully insured plan & 75 full-time employees

• Complete Forms 1094-C and 1095-C, including Parts I and II for each employee.
• The insurance carrier will issue Forms 1095-B for covered individuals.

Scenario 3: Self-insured & 40 full-time employees; self-insured

• The employer is not an ALE.
• File Forms 1094-B and 1095-B for any individuals covered.

Scenario 4: Employee full-time for March-April; self-insured

• File 1095-C and list covered months in Part III.

Scenario 5: Union workforce

• Use the multiemployer plan rules.
• Treat as offered coverage and apply the standard codes.

FAQs

1. If no offer was made, should I still file Form 1095-C?

Yes, all ALEs must file Form 1095-C even if they didn’t offer health coverage.

2. Who receives Form 1095-C?

Every employee who was full-time for at least one month in the year must receive a 1095-C.

3. Is e-filing mandatory?

The IRS mandates e-fling if there are 10 or more total information returns in a year.

4. What are the key filing deadlines?

Send the form to the employees by March 2; E-file with the IRS by March 31; If you’re paper-filing, submit by the late-February deadline.

5. Do related companies file together?

No. Each ALE Member reports under its own EIN and submits one main/summary 1094-C.

Reporting employee health coverage doesn’t have to be complicated.
Tax1099 makes ACA reporting simple and accurate.

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