E-File 1094-C

What is ACA Form 1094-C?

ACA Form, 1094-C "Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns," is an essential form used by Applicable Large Employers (ALEs) under the Affordable Care Act (ACA). Its primary functions and features include:

• Transmittal of Information Returns: Form 1094-C serves as a cover sheet for transmitting Form 1095-C information returns to the IRS. ALEs use Form 1095-C to report details about the health insurance coverage offered to full-time employees, and Form 1094-C helps to summarize and transmit this information.
• Reporting Aggregate Employer-Level Data: In addition to transmitting Form 1095-C returns, Form 1094-C includes aggregate information about the employer, such as total employee count, full-time employee count, and information about offers of coverage.
• Supporting Compliance with Employer Mandate: The information reported on Form 1094-C assists the IRS in enforcing the ACA's employer mandate, which requires ALEs to offer affordable, minimum essential coverage to full-time employees or potentially face penalties.
• Indicating Transitional Relief or Other Options: Employers may use Form 1094-C to indicate eligibility for specific transitional relief or other options available under the ACA.

In summary, Form 1094-C is a critical component of the ACA's reporting requirements for large employers. Proper completion and timely submission of this form are vital for compliance with healthcare regulations and to avoid potential penalties.

What information is required to file form 1094-C?

When filing ACA Form 1094-C, "Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns," Applicable Large Employers (ALEs) must provide the following information:

• Employer Information: Includes the employer's name, Employer Identification Number (EIN), address, and contact details.
• Aggregated Employer Group Information: If the employer is part of an aggregated employer group, information about other entities in the group must be provided.
• Total Number of 1095-C Forms: The number of 1095-C forms being transmitted with the 1094-C form.
• Total Employee Count: Information about the total number of employees, including both full-time and part-time employees.
• Full-Time Employee Count: The number of full-time employees for each month of the year.
• Information About Offers of Coverage: Details about the health coverage offered, including whether Minimum Essential Coverage (MEC) was offered to full-time employees and their dependents.
• Transitional Relief and Other Options: Indication of any transitional relief or other options that the employer is using under the ACA.
• Signature: An authorized signature, attesting to the accuracy of the information provided.

Properly completing Form 1094-C is essential for compliance with the ACA's reporting requirements for large employers.

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When is the deadline to submit form 1094-C?

The deadlines for submitting ACA Form 1094-C, "Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns," vary based on the method of filing:

• Electronic Filing: If filing electronically, the deadline is Monday, March 31^st, 2025. Electronic filing is mandatory for Applicable Large Employers (ALEs) that are filing 10 or more Form 1095-C returns.
• Paper Filing: If filing on paper (permitted for those submitting fewer than 10 Form 1095-C returns), the deadline is Friday, February 28^th, 2025.

These deadlines are subject to change, and it's essential to consult the IRS instructions or the IRS website for the most current information. Missing the deadline can result in penalties, so timely filing is critical. Employers may also explore the possibility of obtaining an extension if needed.

What is the penalty for not submitting form 1094-C?

Failure to submit ACA Form 1094-C, "Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns," or submitting it with incorrect information, can result in penalties. The specific penalties may include:

• Penalty for Failure to File: A penalty may be assessed for failing to file Form 1094-C by the required deadline. For tax year 2024, this penalty is generally $330 per return, with a maximum annual penalty of $3,783,000
• Penalty for Incorrect Information: If Form 1094-C is filed with incorrect or incomplete information, there may be a penalty. This penalty is also generally $330 per return, with the same maximum, if the error is not corrected within the required time frame.
• Intentional Disregard: If the failure to file is due to intentional disregard of the filing requirements, the penalty per return is greater, with no maximum limit.
• Adjustments for Smaller Businesses: Lower maximum penalties may apply to organizations with gross receipts of $5 million or less.
• Possible Penalty Abatement: Penalties may be abated if the failure was due to reasonable cause and not willful neglect.

It's essential to note that these penalties are subject to change. Timely and accurate filing of Form 1094-C is crucial to avoid these penalties.

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What are the ICHRA reporting requirements?

Employers that sponsor an Individual Coverage Health Reimbursement Arrangement (ICHRA) must satisfy both Affordable Care Act (ACA) information‑return rules and a separate employee‑notice obligation. The precise filing package depends on employer size and funding method:

• Which IRS form?
  • Non‑ALE, self‑insured (including level‑funded) employers: file Forms 1095‑B with transmittal Form 1094‑B under §6055.
  • Applicable Large Employers (50+ full‑time equivalents): file Forms 1095‑C and transmittal Form 1094‑C. When an ICHRA is offered, Line 14 must use one of the ICHRA codes 1L–1U (e.g., 1M for employee + dependent offer). The employee’s age, ZIP‑code safe harbor, and required contribution go on Lines 15–17.
• Dual reporting tracks:
  • §6055 (Minimum Essential Coverage): Shows who actually had coverage.
  • §6056 (Employer Mandate): Shows which full‑time employees received an offer of coverage and whether it was affordable.
  ALEs that self‑fund an ICHRA satisfy both sections on a single Form 1095‑C.
• Employee notice: A model ICHRA notice must be delivered at least 90 days before the start of each plan year (or by the benefit‑eligibility date for mid‑year entrants). The notice explains the allowance amount, opt‑out rights, and how an ICHRA affects premium‑tax‑credit (PTC) eligibility. Electronic delivery is permitted with consent.
• Deadlines for the 2024 tax year (reported in 2025):
  • Recipient copies (1095‑B/‑C): automatically extended to Monday, March 3^rd, 2025.
  • IRS filing: Paper—Friday, February 28^th, 2025 (available only if you file less than 10 total information returns) Electronic—Monday, March 31^st, 2025.
• Record retention: Keep copies of every notice, Form 1094/1095, and supporting census or payroll data for at least three years in case of IRS or employee inquiries.

Because the affordability safe‑harbor percentage, ICHRA codes, and filing thresholds can change annually, always confirm the current‑year instructions before you prepare returns.

What are the state filing requirements for Form 1094‑C / 1095‑C?

Five U.S. jurisdictions now enforce their own individual‑mandate laws and therefore require employers to transmit ACA data directly to the state—usually copies of the same 1094‑C/1095‑C set you file with the IRS. Below is a 2025 snapshot (2024 coverage year):

• California (FTB):
  • Recipient copies: Friday, January 31^st, 2025
  • State e‑file: Monday, March 31^st, 2025 (XML upload only; no paper option)
• District of Columbia (MyTax DC):
  • Recipient copies: Friday, January 31^st, 2025
  • State e‑file: Monday, March 31^st, 2025 (30 days after the federal deadline)
  • All forms must be transmitted electronically.
• Massachusetts (DOR │ MassTaxConnect):
  • Form MA 1099‑HC to employees and to the state—both due Friday, January 31^st, 2025. ALEs also transmit their 1095‑C data via XML.
• New Jersey (Division of Taxation):
  • Recipient copies: Monday, March 3^rd, 2025 (follows the federal extension)
  • State e‑file:Monday, March 31^st, 2025
• Rhode Island (RI Division of Taxation):
  • Recipient copies:Monday, March 3^rd, 2025
  • State e‑file: Monday, March 31^st, 2025

Electronic filing is mandatory in California, D.C., Massachusetts, and Rhode Island, and strongly encouraged elsewhere. States assess their own late‑ or non‑filing penalties on top of federal amounts, so verify local rules each year.

Due to the potential complexity and variability of state filing requirements for Form 1094-C, employers should consult state regulations, guidance, and possibly seek legal or tax professional assistance to ensure compliance with all applicable state requirements.

Which states that have ACA reporting requirements?

Several states have implemented or were considering their own health coverage reporting requirements, which may include filings similar to or in addition to ACA Form 1094-C. Some of these states include:

• California: California has implemented its own state-level individual mandate and requires certain reporting from employers.
• New Jersey: New Jersey's state-level individual mandate includes reporting requirements for employers and coverage providers.
• Massachusetts: Massachusetts has longstanding reporting requirements related to health coverage, including employer reporting.
• Washington, D.C.: The District of Columbia has also implemented a local individual mandate with associated reporting requirements.
• Rhode Island: Rhode Island has enacted a state-level individual mandate that includes specific reporting obligations.
• Vermont: Vermont has considered health coverage reporting requirements that may affect employers and coverage providers.