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1094 & 1095 Reporting Requirements – Your complete guide to ACA employer reporting for the 2025 tax year — including who must file, which forms to use, key deadlines, penalty amounts, and the new optional distribution method.
What Are Forms 1094 and 1095?
Under the Affordable Care Act (ACA), employers are required to report health insurance coverage information to the IRS and to the individuals they cover. This reporting is carried out using two sets of forms: the 1094 series (transmittal forms) and the 1095 series (individual statements).
The reporting obligation covers the 2025 tax year, with all filing and furnishing activities taking place in early 2026. Whether you are an Applicable Large Employer (ALE) or a small employer sponsoring a self-insured plan, understanding which forms to file, by when, and how is essential to staying compliant and avoiding costly IRS penalties.
Who Must File: Understanding the Reporting Obligation
The IRS requires ACA reporting from two main groups of employers:
1. Applicable Large Employers (ALEs) — Forms 1094-C and 1095-C
An ALE is an employer that employed an average of 50 or more full-time employees, including full-time equivalent (FTE) employees, during the prior calendar year. For the 2025 tax year, ALE status is determined based on 2024 employment counts.
ALEs must file Forms 1094-C and 1095-C regardless of whether they offer a health plan. This covers ALEs with fully insured plans, self-insured plans, and those offering Individual Coverage Health Reimbursement Arrangements (ICHRAs).
2. Small Employers with Self-Insured Plans — Forms 1094-B and 1095-B
Small employers (non-ALEs) that sponsor a self-insured or level-funded health plan, including ICHRAs, must file Forms 1094-B and 1095-B. Notably, small employers with fully insured plans are not required to file at all — that obligation falls on the insurance carrier.
The only employers exempt from 2026 ACA reporting are small employers (non-ALEs) that either sponsored a fully insured medical plan for all 12 months of 2025, or did not sponsor medical benefits at all in 2025.
Overview of the Four ACA Reporting Forms
| Form | Description | Filed By | Accompanied By |
| 1094-B | Transmittal for Health Coverage Information Returns | Small employers (non-ALEs) with self-insured plans | Forms 1095-B |
| 1095-B | Health Coverage statement for individuals | Small employers (non-ALEs) with self-insured plans; also carriers for fully insured plans | Form 1094-B |
| 1094-C | Transmittal of Employer-Provided Health Insurance Offer and Coverage | All ALEs | Forms 1095-C |
| 1095-C | Employer-Provided Health Insurance Offer and Coverage | All ALEs | Form 1094-C |
Key 2026 Filing Deadlines for the 2025 Tax Year
The IRS has confirmed that forms and deadlines for 2025 ACA reporting are unchanged from prior years. Here is a summary of all critical dates:
| Deadline | Date | Applies To |
| Furnish 1095-B/C to individuals | March 2, 2026 | All employers subject to ACA reporting (ALEs and non-ALE self-insured sponsors) |
| Paper filing with IRS | March 2, 2026 | Employers filing 10 or fewer information returns in aggregate (very limited) |
| Electronic filing with IRS | March 31, 2026 | All employers filing 10 or more information returns (most employers) |
| PCORI Fee due | July 31, 2026 | Applicable self-insured plan sponsors |
| State filings (varies) | March–April 2026 | Employers with employees in CA, NJ, MA, RI, DC, and other mandate states |
Note: The furnishing deadline of March 2, 2026 reflects a permanent automatic 30-day extension from the statutory January 31 deadline, as established by IRS regulations. No additional extensions are available beyond this date.
Electronic Filing Requirement
Since January 2024, the IRS electronic filing threshold has been lowered significantly. Employers who file 10 or more information returns in aggregate — including W-2s, 1099s, 1098s, and 1095s — must file electronically.
This means virtually all employers subject to ACA reporting are required to file electronically through the IRS Affordable Care Act Information Returns (AIR) system. The penalty for failure to file electronically (when required) is $340 per return.
What’s New for 2025: Alternative Statement Furnishing Method
One significant update for the 2025 reporting season is the formalization of an alternative manner of furnishing 1095 statements to individuals. Under the Paperwork Burden Reduction Act, ALEs and non-ALE self-insured sponsors are no longer required to automatically mail a Form 1095 to every covered individual.
Instead, employers may satisfy the furnishing requirement by posting a clear, conspicuous, and accessible notice on their public-facing website. This notice must:
- Be posted no later than March 2, 2026 and remain on the website through at least October 15, 2026
- Inform individuals that they may request a copy of their Form 1095-B or 1095-C
- Result in the form being furnished no later than January 31, 2026, or 30 days after the date of the request — whichever is later
Important Exception: New Jersey requires employers to proactively furnish Form 1095 to all NJ residents — the website-notice alternative does not satisfy the state’s requirement. Employers with New Jersey employees must still distribute statements directly.
Form 1095-C: What ALEs Must Report
Form 1095-C is the primary ACA disclosure document used by ALEs. It is completed for each full-time employee and includes three key sections:
| Part | What It Covers |
| Part I — Employee and Employer Information | Employee’s name, SSN, address; employer name, EIN, and contact information |
| Part II — Employee Offer and Coverage | Whether coverage was offered, the lowest employee contribution amount (Line 15), and safe harbor codes (Line 16) |
| Part III — Covered Individuals (Self-Insured Plans Only) | Names, SSNs, and months of coverage for the employee and enrolled dependents — required only if the ALE sponsors a self-insured plan |
ALEs using Individual Coverage HRAs (ICHRAs) must also complete Part II with the applicable offer code and the employee’s age as of January 1, 2025.
Form 1094-C: The Authoritative Transmittal
Form 1094-C is the transmittal cover form that accompanies the package of 1095-C forms submitted to the IRS. ALEs may file more than one Form 1094-C (for example, for different operating divisions), but one must be designated as the Authoritative Transmittal.
The Authoritative Transmittal (Line 19, Box checked ‘Yes’) must report the aggregate ALE-wide data, including total number of Forms 1095-C filed, whether the ALE is part of an Aggregated ALE Group, and information about offers of coverage under the employer mandate.
2025 ACA Reporting Penalties
Failing to comply with ACA reporting requirements can result in significant penalties. The 2025 penalty amounts (applicable to filings due in 2026) are as follows:
| Violation | Penalty Per Return | Annual Cap |
| Failure to file a correct information return with IRS | $340 | $4,098,500 |
| Failure to furnish a correct payee statement to individual | $340 | $4,098,500 (separate cap) |
| Corrected within 30 days of required due date | $60 | Reduced cap |
| Corrected by August 1, 2026 | $130 | Reduced cap |
| Intentional disregard | $680 minimum | No cap |
| Failure to file electronically (when required) | $340 per return | Separate penalty |
ALEs should also be aware of a new six-year statute of limitations for Section 4980H employer shared responsibility penalties. The six-year period does not begin until all accurate and complete forms have been submitted to the IRS — meaning errors or missing forms delay the clock.
2025 ACA Affordability Threshold
For the 2025 plan year, the ACA affordability threshold is 9.02% of an employee’s household income. This means the lowest-cost self-only plan option an ALE offers must not require the employee to contribute more than 9.02% of their household income. For the 2026 plan year, this threshold increases to 9.96%.
ALEs may use one of three IRS safe harbors to determine affordability: the W-2 Safe Harbor, the Rate of Pay Safe Harbor, or the Federal Poverty Line (FPL) Safe Harbor. The FPL safe harbor for 2025 applies where the employee’s monthly contribution for the cheapest self-only major medical plan does not exceed $113.20/month.
State-Level ACA Reporting Requirements
In addition to federal IRS filing, several states with their own individual health coverage mandates require separate reporting. Employers with employees in these jurisdictions must file with both the IRS and the applicable state agency:
| State | Who Must File | Deadline | Notes |
| California | Insurance carriers and self-insured employers covering CA residents | ~March 31, 2026 (30 days after IRS deadline) | File via CA Franchise Tax Board (FTB) |
| New Jersey | All employers (fully insured and self-insured) with NJ residents | March 31, 2026 (electronic) | Must proactively furnish 1095 to NJ residents; only Parts I & III of 1095-C required |
| Massachusetts | Insurance carriers and employers covering MA residents | Varies | State uses its own MA form in addition to federal forms |
| Rhode Island | Self-insured employers and carriers with RI residents | ~March 31, 2026 | File via RI Division of Taxation |
| Washington, D.C. | Employers covering D.C. residents | 30 days after IRS deadline | Electronic filing only; no separate individual statement required |
Multi-state employers should verify state-specific requirements and deadlines annually, as requirements can change. Vermont currently has no state-specific form; individual residents report their own coverage.
Streamlined Reporting Options for ALEs
Qualifying Offer Method
ALEs that meet the federal poverty line affordability safe harbor and offered coverage to an employee’s spouse and dependents may use the Qualifying Offer Method. Under this method, the ALE uses Code 1A on Line 14 of Form 1095-C and leaves Line 15 blank. The ALE must check the ‘Qualifying Offer Method’ box on Line 22 (Box A) of Form 1094-C.
98% Offer Method
Under the 98% Offer Method, an ALE that offers MEC to at least 98% of its full-time employees and their dependents may avoid reporting monthly full-time employee counts on Form 1094-C. This method is generally only recommended in specific circumstances.
2025–26 ACA Reporting Compliance Checklist
Use this checklist to stay on track:
- Confirm ALE status for 2025 based on 2024 full-time and FTE average headcount
- Determine which forms apply (1094/1095-C for ALEs; 1094/1095-B for non-ALE self-insured sponsors)
- Gather employee data: offers of coverage, contribution amounts, months covered, and dependent enrollment data (for self-insured plans)
- Choose furnishing method: mail 1095s to employees by March 2, 2026, or post the required website notice by March 2, 2026
- File electronically via the IRS AIR system by March 31, 2026
- Handle state filings if operating in CA, NJ, MA, RI, or D.C.
- Review affordability: confirm employee contributions did not exceed 9.02% threshold for 2025
- Retain records for at least six years given the new statute of limitations for Section 4980H penalties
Frequently Asked Questions
Do I have to mail Form 1095-C to every employee?
No. For tax year 2025, ALEs may satisfy the furnishing requirement by posting a website notice by March 2, 2026, and furnishing a copy upon request. However, this option does NOT apply in New Jersey, where direct distribution to NJ residents remains mandatory.
What is the difference between Form 1094 and Form 1095?
Form 1094 is the transmittal (cover sheet) that accompanies a batch of 1095 forms submitted to the IRS. Form 1095 is the individual statement provided to each employee or covered individual. Think of Form 1094 as the envelope summary and Form 1095 as the letter inside.
Can I request an extension for electronic filing?
Employers may request an extension of time to file with the IRS (not to furnish to employees) using Form 8809. This provides an automatic 30-day extension for the IRS filing deadline, subject to IRS approval. No extension is available beyond the March 2, 2026 furnishing deadline.
What if an employee does not have an SSN?
Form 1095-C may only be used if the employee has a Social Security Number (SSN). If an SSN is unavailable, the IRS instructs employers to use the taxpayer identification number (TIN) or take steps to obtain the SSN before filing.
What is the AIR system?
The IRS Affordable Care Act Information Returns (AIR) system is the IRS electronic filing portal for ACA reporting. All employers required to file electronically must register with the AIR system and submit Forms 1094/1095 in the IRS-specified XML format, either directly or through a third-party transmitter.
Final Thoughts
ACA 1094 and 1095 reporting is a complex, annual compliance obligation that affects most employers with 50 or more full-time employees as well as smaller employers with self-insured plans. For the 2025 tax year (reported in 2026), the forms, codes, and deadlines remain largely unchanged — but the formalized alternative furnishing method and the new six-year statute of limitations for employer shared responsibility penalties are important developments to factor into your compliance strategy.
Given the high per-return penalties and the new six-year lookback period, it pays to get ACA reporting right from the start. Many employers work with ACA reporting vendors, benefits brokers, or compliance consultants to manage the process efficiently and reduce risk.
Official Resources: IRS.gov/Form1094C | IRS.gov/Form1095C | IRS Instructions for Forms 1094-C and 1095-C (2025) | IRS.gov/irb/2025-11_IRB#NOT-2025-15
Disclaimer: This article is for informational purposes only and does not constitute legal, tax, or compliance advice. Consult a qualified benefits attorney or compliance professional for guidance specific to your organization.