Key Takeaways
- Form 8809 only extends IRS filing for Forms 1094-C and 1095-C.
- A timely first extension generally adds 30 days automatically.
- For tax year 2026, Forms 1094-C and 1095-C are due to the IRS by March 1, 2027, if filed on paper, or March 31, 2027, if filed electronically.
- A second extension is possible only with a signed paper Form 8809 and a qualifying hardship reason.
- 1099Online lets employers request the Form 8809 extension and continue preparing their ACA filing in one workflow.
Applicable Large Employer Members may reach the ACA filing season with employee information still going through reviews, unresolved or partially resolved coverage codes, or Form 1094-C totals not fully reconciled.
A timely 1095-C filing extension can give an employer additional time to submit Forms 1094-C and 1095-C to the IRS. The extension is requested with Form 8809 and generally adds 30 days to the applicable IRS filing deadline.
What Is a 1095-C Filing Extension?
Form 1095-C reports ACA offer-of-coverage information for full-time employees of an ALE Member, and Part III reports covered individuals when a self-insured ALE Member must report enrollment. Form 1094-C accompanies those employee forms and reports employer-level information to the IRS.
If an employer cannot complete the ACA filing by the normal deadline, it can generally request a Form 1095-C extension using Form 8809, Application for Extension of Time To File Information Returns.
For Forms 1094-C and 1095-C, a timely initial Form 8809 generally provides an automatic 30-day extension. The filer does not have to prove hardship or provide an explanation for this first extension.
The extension does not change:
- ALE reporting status
- Employees who must be included
- Form 1095-C Lines 14–16 requirements
- Part III reporting for applicable self-insured ALE Members
- Form 1094-C requirements
- Separate employee-statement obligations
Form 1095-C Filing Extension Deadlines for Tax Year 2026
Forms 1094-C and 1095-C have separate IRS filing deadlines for paper and electronic filing.
| Filing Requirement | Tax Year 2026 Deadline | Extension Rule |
|---|---|---|
| Paper filing with the IRS | March 1, 2027 | Timely Form 8809 generally adds 30 days. |
| Electronic filing with the IRS | March 31, 2027 | Timely Form 8809 generally adds 30 days. |
| Initial Form 8809 request | No later than the applicable original filing deadline | Automatic 30-day extension. |
| Additional extension request | Before the first extension expires | Up to 30 additional days if requirements are met. |
February 28, 2027, falls on a Sunday, so the paper ACA reporting deadline moves to Monday, March 1.
Employers required to file electronically should use March 31, 2027, as their original IRS filing deadline.
How to Request a 1095-C Filing Extension with Form 8809
Step 1: Confirm how the ACA returns will be filed
Employers generally need to eFile when they have 10 or more information returns in total, counted in the aggregate. Forms 1094-C and 1095-C are electronically transmitted through the IRS Affordable Care Act Information Returns (AIR) system.
The extension request is separate from the ACA transmission. Employers should submit Form 8809 on paper or e-file it through IRIS for the 2027 filing season.
Step 2: Complete Form 8809
The extension request includes basic filer information such as:
- Legal filer name
- Address
- Taxpayer identification number
- Contact information
- Paper or electronic filing method
- Forms being extended
Select Forms 1094-C and 1095-C as applicable.
The legal name and TIN should match IRS records. A mismatch can cause trouble with extension processing.
Step 3: Submit Form 8809 on time
An automatic extension request should be filed as soon as the employer knows more time will be needed, but not before January 1 of the year in which the returns are due.
For tax year 2026, that means filing during 2027 and no later than the applicable original Form 1094-C and 1095-C filing deadline.
The automatic first extension generally is not available if Form 8809 is filed after the original IRS filing deadline.
Step 4: Use the extension period for accuracy checks
The best way to use the extra 30 days would be to complete unfinished ACA work and review:
- Employee names and SSNs
- ALE Member name and EIN
- Line 14 offer-of-coverage codes
- Line 15 employee required contribution amounts
- Line 16 Section 4980H codes
- Part III covered individual data, when applicable
- Total number of full-time employees
- Form 1094-C employer totals
- Any corrected payroll or benefits records
Can Employers Get a Second 1095-C Filing Extension?
Potentially. An employer that already received the first automatic 30-day extension may request one additional 30-day extension. Unlike the first extension, the second request is not automatic.
The employer must:
- Have obtained the initial extension.
- Request the additional extension before the first one expires.
- Submit the additional request on paper Form 8809.
- Complete the hardship section.
- Sign the request.
Qualifying circumstances listed on Form 8809 include situations such as:
- A catastrophic event in a federally declared disaster area
- Fire, casualty, or natural disaster affecting operations
- Death, serious illness, or the unavoidable absence of the person responsible for filing
- The filer is in its first year of establishment
- Required payee information is not being received in time to prepare an accurate return
Does Form 8809 Extend the Employee 1095-C Deadline?
No. A 1094-C and 1095-C extension through Form 8809 applies to filing the information returns with the IRS. Employee furnishing is a separate compliance requirement.
The IRS has also changed ACA statement-furnishing rules in recent years, including an alternative website-notice method for qualifying employers.
Current general IRS procedures reference Form 15397 for certain recipient-statement extension requests. However, the latest Form 1095-C-specific instructions provided an automatic furnishing extension and stated that no additional furnishing extension would be granted.
Employers preparing 2026 Forms 1095-C should therefore check the final 2026 instructions before assuming that Form 15397 is available for an additional employee-statement extension.
What Happens If You Miss the 1095-C Filing Deadline?
An employer that misses both the original filing deadline and the IRS Form 8809 deadline generally cannot obtain the automatic extension afterward.
If the deadline has passed, complete and file Forms 1094-C and 1095-C as soon as possible.
IRC Section 6721 may also impose information-return penalties for late, incorrect, and missing information returns. This amount may vary, depending on how quickly the employer files a correct return. Separate penalties may apply to failures involving employee statements.
Penalties can be substantially higher for intentional disregard.
Employers should be able to explain why the filing was late and what steps they took to correct it. In certain situations, they may be eligible for reasonable-cause relief, but it cannot be assumed.
Common 1095-C Extension Scenarios
| Scenario | Result | Employer Action |
|---|---|---|
| The employer cannot meet the March 31 e-file date | Initial extension is generally available | File Form 8809 by March 31. |
| The first extension will not be enough | The second extension may be available | Submit a signed paper Form 8809 before the first extension expires and meet hardship rules. |
| Employee statements are the issue | Form 8809 does not extend furnishing | Follow the final 2026 Form 1095-C furnishing guidance. |
| The extension deadline has passed | Automatic extension is generally unavailable | Complete and file returns promptly. |
| Benefits data changes during the extension period | Forms may need updated coding | Reconcile Lines 14–16 and coverage information before filing. |
| Employer files 10 or more information returns | Electronic filing is generally required | Submit ACA returns through AIR. |
How to File Form 1095-C With 1099Online After an Extension
After receiving an extension, the employer still needs to complete and file the ACA returns by the extended deadline.
1099Online provides an online ACA filing workflow for preparing Forms 1094-C and 1095-C and transmitting supported filings through IRS AIR.
Step 1 – Add the employee information
Start with the ALE Member and employee details. You can enter them one at a time or import them in bulk if you are filing for many employees. Before moving on, make sure names, SSNs, addresses, and the employer EIN are correct.
Step 2 – Enter the monthly coverage details
Form 1095-C then asks for the coverage information that applies to each month:
- Line 14: The type of coverage offered
- Line 15: The employee’s required contribution, if this line applies
- Line 16: The applicable Section 4980H code
- Part III: Details of covered individuals for self-insured ALE Members
Step 3 – Review Form 1094-C
Confirm that employer-level information agrees with the Forms 1095-C being transmitted.
The transmittal should accurately reflect the ALE Member’s filing and applicable employee counts.
Step 4 – Submit through AIR
After reviewing the filing, submit the ACA returns electronically through the IRS AIR system and monitor the filing acknowledgment.
If the IRS returns errors, review them and correct the affected records as soon as possible.
FAQs
1. How do I get an extension to file Form 1095-C?
You can request extra time by filing Form 8809 by the original IRS filing deadline. If filed on time, it generally gives you an additional 30 days to file Forms 1094-C and 1095-C. 1099Online also lets you prepare and submit your Form 8809 extension request online.
2. What is the Form 1095-C filing deadline for tax year 2026?
The IRS filing deadlines for Form 1095-C are March 1, 2027, for paper filing and March 31, 2027, for electronic filing.
3. Can I get a second extension for Form 1095-C?
Potentially. An additional 30-day extension may be requested before the first extension expires, but it requires a signed paper Form 8809 and a qualifying hardship reason.
4. Does Form 8809 extend the employee Form 1095-C deadline?
No. Form 8809 extends filing with the IRS only. Employee-statement requirements follow separate rules.
5. Can I file Form 1095-C with 1099Online after receiving an extension?
Yes. The extension simply changes the IRS filing deadline. Employers can use 1099Online to prepare, review, and submit supported ACA returns through the AIR filing workflow.
Secure Your ACA Filing Extension
Running behind on ACA filing? 1099Online helps you request a Form 8809 extension and continue preparing your Forms 1094-C and 1095-C in one simple workflow.