1095-C Filing Requirements: ACA Reporting Rules for Applicable Large Employers

For Applicable Large Employers (ALEs), ACA reporting is an annual requirement. Form 1095-C is used to report health coverage offers to full-time employees and the IRS. Because the form requires month-by-month reporting, if there are even small gaps in payroll, HR, or benefits data, those can lead to corrections, penalties, or compliance issues down the line.

In this blog, we cover 1095-C filing requirements, who must file, what information to report, key deadlines, and best practices for staying compliant. Here’s what employers need to know.

Understanding Form 1095-C Obligations for Employers

As an ALE, your ACA reporting responsibilities go beyond simply issuing Form 1095-C. You’re required to report to both the IRS and your full-time employees about the health coverage you offered during the year, regardless of whether those employees enrolled in your health plan.

In general, an employer qualifies as an ALE if it averaged at least 50 full-time employees, including full-time equivalent employees, during the previous calendar year. For ACA reporting purposes, a full-time employee is generally someone who averages 30 hours of service per week or 130 hours in a month.

Your 1095-C filing requirements generally fall into two categories:

1. Reporting offers of health coverage

As an ALE, you must report whether you offered minimum essential coverage to each full-time employee for every month of the reporting year. This information is reported in Part II of Form 1095-C using IRS indicator codes that reflect the type of coverage offered, employee affordability, and any applicable safe harbor provisions.

Because the form requires month-by-month reporting, your payroll, HR, and benefits records should align to ensure the information reported is accurate.

2. Reporting enrollment for self-insured plans

If you’re a self-insured employer, you have additional reporting obligations. Along with reporting the offer of coverage, you must also report the individuals who were enrolled in your self-insured health plan. Self-insured ALE Members must use Form 1095-C and transmittal Form 1094-C. This information is reported in Part III of Form 1095-C and may include employees, their spouses, dependents, retirees, or other covered individuals, as applicable.

Part III reporting may still be required even if an employee wasn’t full-time for every month of the year, provided they were enrolled in your self-insured health plan during the reporting period. If the employer is a non-ALE, it must use Form 1095-B, Health Coverage, and transmittal Form 1094-B, Transmittal of Health Coverage Information Returns, to report minimum essential coverage.

Form 1095-C Filing Requirements

For 2026 plan years, the affordability percentage increases to 9.96%, up from 9.02% for 2025 plan years. Employers use this percentage to check whether the health coverage they offer is affordable. The result may affect the codes reported on Form 1095-C filed in 2027.

Who Must File Form 1095-C?

Each ALE member has to file Form 1095-C for every employee who was a full-time employee for at least one month during the calendar year. If you’re part of an aggregated or controlled group, each ALE member is responsible for filing separately under its own EIN.

The self-insured employer 1095-C rules go a step further. Self-insured ALEs must also report individuals enrolled in their coverage, which can include certain employees who weren’t full-time throughout the year.

What Information Is Required?

Form 1095-C is divided into three parts:

1095-C Due Date 2027

For 2026 coverage reporting, the key 2027 deadlines are:

You can generally get an automatic 30-day extension for filing with the IRS by submitting Form 8809, Application for Extension of Time To File Information Returns, by the applicable filing due date.

Keep in mind that Form 8809 only extends the IRS filing deadline. It does not automatically extend the deadline for furnishing Form 1095-C statements to employees.

Also, employers may use the ACA alternative furnishing method if they meet the IRS notice and request rules, instead of automatically sending Form 1095-C to every individual. The current IRS instructions say employers no longer have to automatically send Form 1095-C if they provide the required website notice and furnish requested copies on time.

Electronic Filing Requirements

If you are filing 10 or more information returns in aggregate, you must file Forms 1094-C and 1095-C electronically. Electronic Forms 1094-C and 1095-C are transmitted through the IRS ACA Information Returns (AIR) system, not IRIS, with Form 1094-C serving as the transmittal for your Forms 1095-C.

But before you start filing, you have to verify employee names and SSNs, your EIN, monthly coverage codes, affordability information, and self-insured enrollment data. Once this data is submitted, retain your filing records and IRS acknowledgment as proof of submission.

Core filing workflow

Use this workflow to move from employee identification to submission under 1095-C filing requirements:

1. Confirm your ALE status using prior-year full-time and full-time equivalent employee counts.

2. Identify all reportable employees who were full-time for at least one month during the calendar year.

3. Determine whether your coverage is fully insured or self-insured to establish which reporting requirements apply.

4. Complete Part II accurately, including monthly offer-of-coverage, affordability, and applicable safe harbor codes.

5. Complete Part III when required for individuals enrolled in an ALE’s self-insured health plan.

6. Validate filing data such as employee names, SSNs, employer EINs, coverage information, and monthly indicator codes before submission.

7. Prepare Form 1094-C as the transmittal for your Forms 1095-C and furnish employee statements, unless you meet the IRS alternative furnishing rules.

8. File electronically through the ACA Information Returns (AIR) system when required and retain the IRS acknowledgment as proof of submission.

Request additional filing time if necessary. As stated earlier, you can generally obtain an automatic 30-day IRS filing extension by submitting Form 8809 by the applicable due date. This doesn’t automatically extend the deadline for furnishing employee statements.

Staying Compliant and Avoiding Costly Mistakes

Most ACA reporting errors usually come from inconsistencies between payroll, HR, benefits, and employee records and waiting until filing season to reconcile this data, even a small discrepancy can result in incorrect codes, rejected filings, or time-consuming corrections.

Some common mistakes to watch for include:

• Miscalculating ALE status by excluding full-time equivalent employees.
• Missing employees who were full-time for only part of the year.
• Using incorrect Line 14 or Line 16 indicator codes.
• Reporting affordability information that doesn’t align with payroll records.
• Leaving covered individuals out of Part III when reporting self-insured coverage.
• Filing Forms 1094-C and 1095-C through the wrong IRS system.
• Failing to identify the Authoritative Transmittal correctly on Form 1094-C.

Errors can have broader consequences beyond correcting a Form 1095-C. For 2026, the adjusted employer shared responsibility payment is $3,340 under Section 4980H(a) and $5,010 under Section 4980H(b), subject to the specific conditions and calculations that determine whether an ALE owes a payment.

You can reduce compliance risks associated with filing Forms 1094-C and 1095-C.

• Track full-time employee status monthly
• Reconcile coverage offers against payroll and enrollment records
• Validate data like names, SSNs, and EINs before filing

In case you are part of a controlled group, you can start by reviewing your structure early rather than waiting until year-end. You should also maintain a clear process for corrections or rejected filings and retain employee consent records when furnishing Form 1095-C electronically.

Real-Life Scenarios

Conclusion

ACA reporting becomes easier to manage when it’s treated as a year-round process rather than another year-end filing task. Building streamlined reporting practices throughout the year gives you more time to spot discrepancies in codes, resolve them before submission, and approach filing season with fewer surprises.

Ultimately, meeting Form 1095-C filing requirements comes down to having a process that keeps your reporting consistent, verifiable, and ready when it’s time to file.

FAQs

1. Who needs to file Form 1095-C?

Applicable Large Employer (ALE) members generally file Form 1095-C for each employee who was a full-time employee for at least one month during the calendar year.

2. What is the main threshold for Form 1095-C filing?

There is no payment threshold. 1095-C filing requirements are primarily determined by ALE status and the employer’s ACA reporting obligations.

3. Do employers file Form 1095-C through IRIS?

Electronic filing of Forms 1094-C and 1095-C is completed through the IRS ACA Information Returns (AIR) system, not IRIS.

4. When is Part III required on Form 1095-C?

Part III generally applies to self-insured ALEs and reports individuals enrolled in the employer’s self-insured health coverage.

5. Does an employee who was full-time for only one month still need Form 1095-C?

Generally, yes. An ALE must typically report an employee who was full-time for at least one month during the calendar year.