IRS Form 1094-C – Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns – As the Affordable Care Act (ACA) enters its second decade, Applicable Large Employers (ALEs)—those with 50 or more full-time employees—face heightened scrutiny on health coverage compliance. IRS Form 1094-C, the Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns, is the linchpin for reporting offers of minimum essential coverage (MEC) to full-time employees. For the 2025 tax year, with penalties rising to $340 per return and new relief on employee furnishing, accurate filing is non-negotiable to avoid assessments under Section 4980H.
This SEO-optimized guide, based on the official 2025 Instructions for Forms 1094-C and 1095-C (Rev. December 2024) and recent legislative updates like the Paperwork Burden Reduction Act (PBRA), details the form’s role, eligibility, step-by-step completion, deadlines, and pitfalls. Whether you’re an HR leader or compliance officer, mastering Form 1094-C ensures IRS alignment and shields against $2,970 monthly penalties per uncovered employee. Download the 2025 form from IRS.gov and prepare for electronic filing—mandatory for 10+ returns.

What Is IRS Form 1094-C?
Form 1094-C is the transmittal summary for Forms 1095-C, aggregating data on health coverage offers, affordability, and minimum value across an ALE’s full-time workforce. Filed solely with the IRS (not employees), it enables verification of ACA employer shared responsibility provisions, helping assess penalties if fewer than 95% of full-time employees receive affordable MEC.
The form spans four parts:
- Part I: ALE identification and totals.
- Part II: Aggregated ALE Group details.
- Part III: Monthly coverage offer indicators.
- Part IV: Covered individuals summary.
For 2025, no structural changes, but instructions emphasize the new optional alternative furnishing method under Notice 2025-15, allowing on-request 1095-C delivery. It supports IRS cross-checks with employee PTC claims on Form 8962, reducing audit risks.
Key Fact: ALEs must offer MEC to 95% of full-time employees (30+ hours/week) to avoid $2,970/month penalties in 2025—Form 1094-C proves compliance.
Who Must File Form 1094-C?
Filers: Every ALE Member—defined as an entity averaging 50+ full-time equivalents (FTEs) in 2024—must file one or more Forms 1094-C, attaching 1095-Cs for each full-time employee (FTE) in any 2025 month. This includes:
- Standalone ALEs (e.g., corporations with 50+ FTEs).
- Aggregated ALE Groups (common control, e.g., parent-subsidiary), where each member files separately but designates an Authoritative Transmittal.
- Self-insured or fully-insured plan sponsors.
Threshold: Based on 2024 averages; seasonal employers use look-back measurement.
Exceptions:
- Non-ALEs (under 50 FTEs) report via Forms 1094-B/1095-B if self-insured.
- Government entities or multiemployer plans follow special rules (Pub. 5165).
E-file required for 10+ forms; paper allowed under 10, but up to 10 paper returns avoid penalties. One Authoritative Transmittal per group consolidates data.
Step-by-Step Guide: How to Complete IRS Form 1094-C for 2025
Use the 2025 form (Rev. 5/21/25) from IRS.gov; software like BoomTax automates via Excel/XML imports. Aggregate from payroll/HRIS; verify FTE counts per IRS measurement method.
1. Gather Data
- EIN, ALE status, monthly FTE counts (full-time: 30+ hours).
- Coverage offers (95% threshold), affordability safe harbors (W-2, FPL, rate-of-pay).
- 1095-C totals for transmission.
2. Part I: ALE Member Identification (Lines 1–5)
- Line 1: Check “Continuation” if >1 form; designate Authoritative (Line 19, Column (b)).
- Line 2: ALE name, address, EIN (9-digit, no SSN).
- Line 3: Phone/email for contact.
- Line 4: Calendar/specific year (2025).
- Line 5: Total 1095-C forms attached.
3. Part II: Aggregated ALE Group (Lines 6–17)
- Line 6: Check if part of group.
- Lines 7–17: List up to 10 other members’ names/EINs; continue on additional forms if >10.
4. Part III: ALE Member Monthly Information (Lines 18–30)
- Line 18: Total FTEs each month (exclude <130 hours).
- Line 19: Authoritative totals checkbox.
- Columns (a)–(c): Offer indicators (1A–1H codes for 95% offers, affordability).
- Lines 20–23: Covered FTEs, multiemployer plan participation.
- Lines 24–30: Transition relief indicators (if applicable).
5. Part IV: Covered Individuals (Lines 31–34)
- Line 31: Total covered individuals.
- Line 32: Those offered coverage.
- Lines 33–34: Related tax family members.
Pro Tip: Use Pub. 5165 for AIR e-filing validation; test schemas early.
Deadlines and How to File Form 1094-C for 2025
For 2025 coverage (filed in 2026), PBRA shifts furnishing, but IRS filing remains strict:
- Furnish 1095-C to Employees: Optional—upon request only, by later of Jan. 31, 2026, or 30 days post-request. Post notice by March 2, 2026; retain until Oct. 15, 2026.
- File with IRS:
- Paper: March 2, 2026 (up to 10 forms; mail with 1095-Cs).
- Electronic: March 31, 2026 (AIR system; mandatory 10+).
Extensions: Form 8809 for 30 days (pre-deadline); no furnishing extension. E-file via approved vendors; paper to IRS per Pub. 5165.
Common Mistakes to Avoid When Filing Form 1094-C
IRS enforcement via Letters 226J assesses penalties on FTE counts—errors amplify exposure. Here’s a table of 2025 pitfalls:
| Mistake | Why It Happens | How to Fix/Avoid | Potential Penalty |
|---|---|---|---|
| Incorrect FTE Counts (Line 18) | Misapplying 130-hour threshold or seasonal look-back. | Use IRS measurement method; audit payroll monthly. | Inflated 4980H assessments ($2,970/employee/month). |
| Wrong Offer Codes (Part III) | Failing 95% threshold or affordability safe harbors. | Verify 1A–1H codes; test W-2/FPL rates annually (8.39% threshold). | $340/return + no cap for intentional. |
| EIN/Name Mismatches | Typos or truncation errors. | TIN-match via IRS; full 9-digit EIN. | Rejection; $340/form. |
| Aggregated Group Errors (Part II) | Omitting members or wrong Authoritative. | List all; designate one transmittal. | Group-wide penalties. |
| Late E-Filing | Missing March 31 deadline. | Use vendors; apply Form 8809 early. | $340/return (max $4,098,500/year). |
| Ignoring Notice 2025-15 | Auto-furnishing 1095-Cs. | Post notice; respond to requests timely. | $340/statement. |
Correct via “CORRECTED” forms; respond to 226J within 90 days (new ERIA rule).
IRS Form 1094-C Download and Printable
Download and Print: IRS Form 1094-C
2025 Updates and Special Considerations for Form 1094-C
2025 instructions (Rev. Dec. 2024) incorporate PBRA and ERIA relief:
- Furnishing Relief: On-request only for 1095-C (PBRA); post notice by March 2, 2026.
- Response Extension: 90 days for Letters 226J (ERIA, post-Dec. 23, 2024).
- Penalties Up: $340/return ($680 intentional); max $4,098,500.
- E-Filing: 10+ mandatory; Pub. 5165 updates for AIR schemas.
- Affordability: 8.39% threshold; ICHRA age reporting (Jan. 1, 2025).
State mandates (e.g., CA, MA) may require furnishing—check local rules.
Final Thoughts: Achieve ACA Compliance with Form 1094-C
IRS Form 1094-C is your shield against ACA penalties, summarizing coverage to affirm 95% offers in 2025. With furnishing relief easing burdens, focus on accurate e-filing by March 31, 2026—leverage vendors for validation. Download instructions from IRS.gov, audit FTEs quarterly, and consult Pub. 5165 for tech specs. For aggregated groups, designate authority early.
Partner with compliance experts for seamless reporting. This guide is informational; seek professional advice for your ALE.
Not tax advice. Verify at IRS.gov/ACA.
FAQs About IRS Form 1094-C
Who files Form 1094-C in 2025?
ALEs (50+ FTEs) for each member; aggregated groups file separately with one Authoritative.
What is the 2025 e-filing deadline for Form 1094-C?
March 31, 2026 (mandatory 10+ forms).
Do employees get Form 1094-C?
No—only IRS; 1095-C on request per PBRA.
What penalties apply for 2025 Form 1094-C errors?
$340/return; up to $4,098,500/year max.








