Who Must File Form 1095-C? Complete 1095-C Filing Guide 2025

In this blog, we breakdown everything employers need to know about Form 1095-C. Who must file 1095-C? How do you choose 1095-C vs 1095-B? What’s the difference between self-insured vs fully insured 1095-C plan? Keep reading to stay up to date on this important tax form and handle the tax season effectively.

Who Needs 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 who 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. It’s also on you to furnish the copies to the employees.

What happens if you’re not an ALE? But if the plan is self-insured, reporting usually happens on 1094-B/1095-B instead.

Tip: Confirm ALE status by January using last year’s counts. This way, you can chalk out your filing game plan without any hiccups!

What Must Be Filed and Furnished

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.

COBRA, retirees, and non-employees

If an individual isn’t an employee for any month in the calendar year, report their coverage on Form 1095-B, not Form 1095-C.

Common pitfall: Never fill in Part III for a fully insured plan. If you do this, it can trigger IRS rejections or penalties.

Key Deadlines

Refer to the following table for important 1095-C deadlines and e-file mandate to avoid costly penalties. Mark these dates on your calendar!

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. To get extensions for employee furnishing, you have to follow separate steps.

What about penalties? Late or incorrect filing and furnishing are separate penalties. Always keep proof of mailing/e-delivery and IRS acceptance.

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

Simplify Your Staff Count

ACA employer reporting basics starts with determining the accurate number of employees. Here’s an uncomplicated approach to count full-time employees and full-time equivalents without the complex math.

A full-time employee is anyone who works an average of at least 130 hours in a calendar month (about 30 hours per week).

So, to calculate FTEs for the 50+ Test, add up part-time hours, divide by 120, and add that number to full-time headcount.

How to track FT status

• Monthly method: Evaluate each employee’s actual hours every month.
• Look-back method: Best for variable-hour workers. Use a predefined measurement period to average hours and determine ongoing full-time status.

Tip: For the 1094-C monthly counts, pick a consistent counting day such as the first calendar day or the last day of a payroll period to tally headcount.

Note: If an employee was full-time for any month, a Form 1095-C is required for that year.

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 and Quick Checklist

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.

Pre-filing checklist

• Full-time employee roster
• Coverage type
• Line codes
• 1094-C summary counts
• E-filing readiness

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

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.

2. 75 full-time employees; fully insured plan

• 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.

3. 40 full-time employees; self-insured

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

4. Employee full-time for March-April; self-insured

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

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.

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

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