Form 1094-C

What is Form 1094-C?

Form 1094-C is a mandatory IRS form filed by ALEs (Applicable Large Employers). It is used to report whether they offered health insurance to their full-time employees and to submit Form 1095-C. It summarizes employer-level information for the IRS, supporting enforcement of the ACA (Affordable Care Act) requirements. It also helps the IRS determine if your business may owe a penalty under the employer shared responsibility provisions (Section 4980H of the tax code).

The form includes critical details like the number of employees you had each month, whether you offered MEC (Minimum Essential Coverage) to at least 95% of the staff, or whether your business is part of an aggregated ALE group.

You need to file one authoritative Form 1094-C per employer, including all individual Forms 1095-C for your employees. These forms collectively allow the IRS to access compliance and verify an employee’s eligibility for premium tax credits. Please note that Form 1094-C is not directly distributed to employees and strictly for IRS’s use only.

Who needs to file Form 1094-C?

Fundamentally, any employer classified as an ALE needs to file Form 1094-C. Organizations and companies with ≥ 50 full-time or full-time equivalent employees are categorized as ALEs.

If you meet this threshold, you are legally required to file Form 1094-C, even if you didn’t offer coverage.

Each company is treated as a separate ALE Member if your business is part of a commonly owned group (Aggregated ALE Group).
Each ALE Member must file separately for its own employees—no exceptions for smaller entities.
ALE Members must report whether they offered health coverage.
They must also confirm if the coverage meets ACA’s minimum essential coverage and affordability standards.

What information is required on Form 1094-C?

Form 1094-C mandates providing the following critical information:

Employer information like company name, address, and EIN (Employer Identification Number)
ALE member information, including the total number of Forms 1095-C submitted
Eligibility certification to determine the employer’s eligibility for transition relief and other certifications
Number of full-time employees you had each month
Total number of employees (full-time or not) you had each month
If your company is part of a bigger group of related businesses, name those other companies

Please note that Form 1094-C does not involve additional calculations, only accurate headcounts. However, you must be careful with your monthly employee count. To avoid errors, cross-check each section, and avoid counting someone twice or mentioning part-timers as full-time employees.

Additionally, you do not require any additional documents or attachments while submitting Form 1094-C since it is a transmittal for Forms 1095-C.

How do you fill out Form 1094-C?

Follow the instructions below carefully to fill out the Form 1094-C:

Step 1. Complete Part I (ALE Member Information). Fill out the details for the lines below:

Line 1-6: Enter the ALE’s name, EIN, and address here.
Lines 7-8: Write the name and phone number of a contact person at the ALE whom the IRS can contact for questions.
Lines 9-16: Fill out only if a Designated Government Entity (DGE) is filing on behalf of the ALE. If not, you can leave this blank.
Line 18: Enter the number of Forms 1095-C submitted with your Form 1094-C.
Line 19: Check this box if this is the authoritative transmittal. If not, you can skip the Parts II-IV and complete the signature area only.
Line 20: If authoritative, enter the total number of all 1095-C forms being submitted for the ALE across all batches. If you’ve done 50 submissions in one batch and 75 in another, enter ‘125’ here.
Line 21: Write ‘Yes’ if the ALE is part of an Aggregated ALE Group (companies with common ownership or affiliation). Write ‘No’ otherwise.
Line 22: Check any applicable box that describes the offer method the ALE used:

Box A: Check if the ALE made a Qualifying Offer to at least one full-time employee for all months.
Box B and C: These are reserved and should not be selected.
Box D: Check if the ALE offered affordable coverage with minimum value to at least 98% of its full-time employees and offered MEC to their dependents.

Step 2: Complete Part II (ALE Member Information only if Line 19 is checked). This part is only required for authoritative transmittals. You must ensure consistency in this section as it’s largely auto-calculated or cross-referenced from other entries.

Step 3: Complete Part III (ALE Member Monthly Information). Fill out the following for each calendar month:

Column A: Check ‘Yes’ if at least 95% of full-time employees and their dependents were offered MEC. Do not include employees in a Limited Non-Assessment Period.
Column B: Enter the number of full-time employees your organization had each month.
Column C: Enter the total employee count for each month, including full-time, part-time, and those in a Limited Non-Assessment Period.
Column D: If you’ve checked ‘Yes’ in Line 21, check the months when the ALE was part of an Aggregated ALE Group.

Step 4: Complete Part IV (Other ALE Members of Aggregated ALE Group – if applicable). If the ALE is part of an Aggregated ALE Group (as indicated in Line 21), list up to 30 other ALE members in this section. Give legal name of the entity and EIN for each listed member.

Once you have filled in all the above sections, cross-check thoroughly for errors and accuracy. Make sure the form is filled out and no section is left unattended. In addition, submit the form along with the accompanying Forms 1095-C within the designated deadline.

How to submit Form 1094-C?

You can submit Form 1094-C, along with Form 1095-C, to the IRS either via paper or electronically. Let’s go through the correct process for submitting the form:

Choose the correct method of filing. As of Tax Year 2024, the threshold is 10 or more information returns total (across all types, not just 1094/1095). Electronic filing is mandatory unless a waiver is granted.
Strictly adhere to the filing deadlines.
If required, submit electronically. To do so, create an account with IRS e-Services > get approval to use the AIR system > submit through IRS-approved software or a reporting provider using the formatting and technical standards in Pub 5165 and IRS XML schemas > and upload the form with all applicable Forms 1095-C. You can monitor your submission through the AIR system and check if your return is accepted, accepted with errors, or rejected.
For paper filing, print Form 1094-C and all Forms 1095-C in landscape format on official forms (no photocopies or IRS website printouts). Do not fold or staple the forms. If you’re filing many forms, split them into packages, number them carefully, and place Form 1094-C in the first package.

Ensure mailing to the correct IRS address based on your state:

If your business is in AL, AZ, AR, CT, DE, FL, GA, KY, LA, ME, MA, MS, NH, NJ, NM, NY, NC, OH, PA, RI, TX, VT, VA, WV, mail to: Department of the Treasury, Internal Revenue Service Center, Austin, TX 73301.
If your business is in AK, CA, CO, DC, HI, ID, IL, IN, IA, KS, MD, MI, MN, MO, MT, NE, NV, ND, OK, OR, SC, SD, TN, UT, WA, WI, WY, mail to: Department of the Treasury, Internal Revenue Service Center, P.O. Box 219256, Kansas City, MO 64121-9256.
If outside the U.S., mail to: Department of the Treasury, Internal Revenue Service Center, Austin, TX 73301

Only use first-class mail.

If required, request extensions by filing Form 8809 by the original due date to receive an automatic 30-day extension. You can file it by mail or fax, or via online using the FIRE system.

In cases of hardship, you can request a second 30-day extension. Refer to the instructions for Form 8809 for eligibility and documentation requirements.

Keep copies of all submitted Forms 1094-C and 1095-C. Ensure that you can reconstruct the data for at least 3 years from the due date of the return. If you fail to file electronically and without an approved waiver, this can lead to a penalty of $330 per return. Unless you can show reasonable cause.

What is the deadline for filing Form 1094-C?

For paper filing, the deadline is February 28, 2025 (for calendar year 2024). For electronic, it is March 31, 2025. If a deadline falls on a weekend or legal holiday, the due date is changed to the next business day (any day that is not a Saturday, Sunday, or legal holiday).

What are the most common mistakes to avoid for Form 1094-C?

Filing Form 1094-C is a crucial part of the ACA compliance. The form isn’t lengthy, but minute errors can cause IRS penalties or follow-up notices. Here are some of the most common filing mistakes and how you can steer clear of them.

If you miss the filing deadline, late penalties can be as high as $330 per return. Remember that the IRS does not grant time extensions independently; you have to request one. To make sure you do not miss deadlines, mark the important dates on your calendar. If you need to file for more time, file Form 8809 before the due date to obtain a 30-day extension.
If submitting more than one Form 1094-C, one of them must be marked as the authoritative transmittal on Line 19. Ensure only one 1094-C is marked as authoritative. Review each form carefully before submitting. Mark the final one summarizing the total number of Forms 1095-C.
The following incorrect count can also lead to penalties:

Incorrect count of full-time employees
Employees who left during the year for months they did not work
Including part-time or seasonal employees in your full-time count
Not following IRS definitions for ‘full-time’

Strictly use the IRS rule (full-time is at least 30 hours per week or 130 hours per month). Exclude employees in a limited non-assessment period. Also, double-check your monthly employee status before filing.

If your company is part of an Aggregated ALE Group (you’re related to other employers through common ownership), you need to indicate that on Line 21 and list the other members in Part IV. If you’re in an ALE Group, check ‘Yes’ on Line 21 and fill out Part IV with the names and EINs of up to 30 related entities. If you’re not in a group, leave Line 21 unchecked.
Line 22 has checkboxes related to the type of offer method used. Choosing the wrong one (or one that no longer applies) can misrepresent your coverage and trigger penalties. Only check Box A if you qualify for the Qualifying Offer Method. When in doubt, consult the official IRS instructions or get help from a tax advisor.
The number of 1095-Cs listed on Line 18 and Line 20 of Form 1094-C should match the actual number you are submitting. If they don’t, the IRS may send a penalty notice or request clarification. Count your 1095-Cs carefully before filing. Confirm that your totals are accurate on both lines and match the batch you’re sending in.
Make sure every box is checked correctly. It takes only one missed checkbox to create problems. An example is, if you forget to check the box that indicates minimum essential coverage was offered for the entire year, and you miss the deadline, you still receive penalties even if you provided coverage. Check all parts of your 1094-C before sending it. Don’t necessarily trust software or your service providers; make sure to verify it on your own.
Keep copies of your filed forms. If the IRS sends a penalty letter or requests clarification, you’ll need a copy of what you submitted. Without it, you’ll be left guessing what you reported. Save a PDF or printed version of every form you file. Keep these records for at least three years after the filing date.
Watch for code errors on Form 1095-C. Although our blog is entirely focused on Form 1094-C, mistakes on 1095-C, especially with Line 14–16 codes, can also impact your risk of penalties. Double-check that the codes are accurate. Especially if employees had changes in coverage or employment during the year.

How to amend Form 1094-C?

You should file an amended Form 1094-C if you:

Made a mistake on the authoritative transmittal
Provided incorrect information about an applicable large employer (ALE) member
There were errors in Line 19 (aggregated group indicator), Part III (ALE Member Information), or another material part

Here’s how you can amend it:

Use a new Form 1094-C for the same taxable year. Mark the box for “CORRECTED” at the top of the form. You will complete only the corrected information (do not include any previous or unchanged information). Complete Part I, Part II, Part III, and Part IV as applicable- especially Part III if the original transmittal was incorrect.
If you are only correcting a Form 1094-C (and not Form 1095-Cs), do not send any new Form 1095-Cs unless they also need correction.
If you originally filed electronically, you must amend electronically. If you filed by paper, you may amend by paper (follow the IRS mailing instructions).
Keep copies of the original and amended documents for your records.

What should I do if I lost my Form 1094-C?

If you can’t locate your Form 1094-C, don’t worry. But do act fast.

The IRS doesn’t send you a copy, and if they ask for information and send you a penalty notice, you will need the form in order to respond properly.

First, determine whether you filed the form yourself or if a payroll provider, benefits administrator, or third-party service filed it. If a vendor filed the form on your behalf, call them right away – they should have the form filed and can send you a copy. If you filed in-house and can’t find it, check your own in-house records and see if there are internal email confirmations, PDF uploads, or access to the IRS FIRE system if you filed electronically.

If you are unable to recover it, you may have to contact the IRS as needed to establish what was filed. Keep in mind, though, that if the IRS has to be contacted, it may take some time for them to respond, and you may unnecessarily delay the resolution of any issue by not having the 1094-C in hand.

How does Form 1094-C differ from Form 1094-B?

Form 1094-C is filed by larger employers to report health coverage offers, while Form 1094-B is filed by insurance companies or small employers to report the actual health coverage provided. 1094-C supports the employer mandate, and 1094-B supports the individual mandate.