Under the Affordable Care Act (ACA), entities that provide minimum essential coverage (MEC) must report that coverage to the IRS. And Form 1095-B is the information return built specifically for this purpose. It documents and reports which individuals had coverage, the type of coverage provided, and the specific months it was in effect.
Understanding the basics of Form 1095-B filing requirements is important because this form is used by multiple types of filers, from insurance carriers and government agencies to non-ALE employers with self-insured plans and filing correctly can help avoid corrections, penalties, and compliance gaps in your ACA reporting process.
What You Need To Know About Form 1095-B Filing Requirements
The first question most filers face is whether Form 1095-B is the right form at all for the coverage being reported. The ACA uses three different forms (Form 1095-A, 1095-B, and 1095-C) to report health coverage, and each one applies to a different type of coverage and the entity responsible for reporting it.
Form 1095-B is typically filed by providers of minimum essential coverage, such as:
- Health insurance issuers and carriers file it for insured employer-sponsored coverage and individual-market coverage provided outside the Marketplace..
- Employers that are not Applicable Large Employers that sponsor self-insured health plans must file to report their covered individuals.
- Government agencies or program sponsors file it for programs like Medicare Part A, Medicaid, CHIP, and TRICARE.
- Other providers of minimum essential coverage for reporting under Section 6055.
| Coverage Type | Correct Form | Typical Filer |
|---|---|---|
| Qualified health plan offered through Marketplace | Form 1095-A | Marketplace |
| Insured employer or individual outside non-Marketplace coverage | Form 1095-B | Insurance carrier |
| Self-insured employer plan sponsored by a non-ALE | Form 1095-B | Employer or plan sponsor |
| ALE self-insured plan | Form 1095-C | Employer (ALE) |
| Government-sponsored MEC | Form 1095-B | Government agency |
Note: When filing Form 1095-B, include transmittal Form 1094-B. Together, 1094-B and 1095-B filing form a matched pair where the transmittal must align with the batch of returns it accompanies.
Complete Form 1095-B Filing Instructions
The 1095-B instructions can be organized into an eight-step sequence, from confirming filing responsibility through record retention.
Step 1: Confirm the filing entity
Verify that your entity is responsible for reporting minimum essential coverage on Form 1095-B. This prevents duplicate filings and avoids using Form 1095-B when Form 1095-A or 1095-C applies instead.
Step 2: Gather responsible individual and covered individual data
For each coverage record, collect the responsible individual’s name, their SSN or other TIN, a mailing address, and the names and TINs of all covered individuals. If a TIN is unavailable, use the date of birth. You also need each person’s monthly coverage status for the calendar year.
Step 3: Complete Form 1095-B
Form 1095-B has four parts.
Part I identifies the responsible individual. Line 8 requires a code (A through G) identifying the origin of coverage.
Part II applies only to issuers or carriers of insured group health plans. Employers reporting self-insured coverage on Form 1095-B generally skip this section entirely.
Part III identifies the reporting entity, whether that is an insurance company, a self-insured employer, or a government agency. It includes the entity’s name, EIN, address, and a contact number.
Part IV lists each covered individual and shows whether coverage applied for all 12 months or only for specific months. If a person was covered for at least one day in a given month, that month is checked.
Step 4: Prepare Form 1094-B
Form 1094-B serves as the transmittal document for submitting Forms 1095-B to the IRS. Enter the filer’s information and the total count of Forms 1095-B included with the transmittal.
Step 5: Meet furnishing and filing deadlines
The Form 1095-B due date for tax year 2026 are:
| Filing Action | Due Date |
|---|---|
| Furnish Form 1095-B to responsible individual | March 2, 2027 |
| Paper file with IRS | March 1, 2027 |
| eFile with IRS | March 31, 2027 |
February 28 falls on a Sunday in 2027, which shifts the paper deadline to March 1. The recipient-statement deadline includes the automatic 30-day extension.
Step 6: Check whether the alternative furnishing method applies
Eligible filers may post a clear website notice stating that the recipient may request a copy of Form 1095-B to satisfy the Form 1095-B furnishing requirement. This method works only if the notice is posted before the deadline, accessible, and retained for the required period, and requested copies are sent on time.
Step 7: File through the proper channels
Filers below the electronic threshold may paper file, if permitted. Most filers are expected to file electronically.
Step 8: Retain records
After filing, retain copies of all filed forms, enrollment and termination records, TIN solicitation documentation, furnishing proof or website notice evidence, submission acknowledgments, and any correction history.
Common Filing Mistakes and How to Avoid Them
Form 1095-B filing requirements can trip up filers in a few predictable ways.
- Filing the wrong ACA form is the most common error. Self-insured ALEs use Form 1095-B instead of Form 1095-C. Always confirm ALE status and plan type before assigning the form.
- Reporting excepted benefits as minimum essential coverage is another mistake. Stand-alone dental, stand-alone vision, workers’ compensation coverage, and coverage limited to a specified disease or illness do not qualify and should not appear on Form 1095-B.
- Incomplete or incorrect TIN data may cause rejected returns and lead to penalties. Use the proper TIN solicitation procedures and document any cases where date of birth is used
- Leaving out covered dependents or partial-year coverage months is a common operational gap. Reconcile enrollment records against payroll or carrier systems before filing.
Form 1095-B Filing Scenarios
| Scenario | Reporting Result | Correct Form |
|---|---|---|
| Employer with self-insured plan | Employer reports each covered individual directly. | Form 1095-B + Form 1094-B |
| Fully insured small-business plan | Insurance carrier handles the reporting. | Form 1095-B |
| ALE with self-insured coverage | Employer reports under ALE rules. | Form 1095-C + Form 1094-C |
| Government-sponsored coverage | Agency reports enrolled individuals. | Form 1095-B |
| Alternative furnishing method | Compliant website notice satisfies furnishing rules. | Form 1095-B |
| Partial-year dependent coverage | Report exact months of coverage. | Form 1095-B |
| Missing dependent TIN | Use date of birth if TIN is not available. | Form 1095-B |
Conclusion
Form 1095-B filing requirements work best when the reporting entity first confirms its responsibility. Following a structured process for collecting data form completion, transmittal preparation, and deadline tracking help reduce corrections and keep ACA reporting compliant.
FAQs
1. Who must file Form 1095-B?
Entities that provide minimum essential coverage (MEC) must file Form 1095-B unless another ACA form applies instead.
2. What is Form 1094-B used for?
Form 1094-B is the transmittal form that accompanies Forms 1095-B when submitted to the IRS.
3. Do all employers file Form 1095-B?
No. For insured plans, the carrier typically handles reporting. ALEs with self-insured plans report on Form 1095-C.
4. What information goes in Part IV of Form 1095-B?
Part IV lists each covered individual by name and TIN and shows the months during which minimum essential coverage applied.
5. Can a filer avoid mailing every Form 1095-B automatically?
Yes. Eligible filers may use the alternative furnishing method by posting a compliant website notice and providing the form upon request.
Stay ACA-compliant with faster, error-free Form 1095-B filing.