Form 1095-C Instructions: An Employer’s Guide to ACA Reporting and Filing

What Does Form 1095-C Report?

Form 1095-C is the ACA information return that an Applicable Large Employer (ALE) uses to report health coverage offered to full-time employees.

It reports the Minimum Essential Coverage (MEC) that was offered each month, whether that coverage provided minimum value, and, for self-insured plans, which individuals were enrolled.

For ALE members with self-insured health plans, Form 1095-C identifies the employees and family members who were enrolled during each month.

The IRS uses this form alongside Form 1094-C to administer the employer shared responsibility rules and determine eligibility for premium tax credit rules.

Understanding Form 1095-C instructions starts with ALE status:

• ALE threshold: 50 or more full-time employees, including full-time equivalents, in the prior year.
• Aggregated groups: Related entities under common ownership or similar arrangement are counted together to determine ALE status.
• Separate filing: Each ALE member has to file under its own EIN.

Who Files Form 1095-C?

Employers that qualify as an ALE member have to file a Form 1095-C for every employee who was full-time for at least one month during the calendar year, even if that member itself has fewer than 50 full-time employees.

ALE members with employer-sponsored self-insured health plans must also complete Part III to list all enrolled individuals, including spouses, dependents, and certain nonemployees.

Employers that are not ALEs but sponsor self-insured plans report coverage on Forms 1094-B and 1095-B instead.

Form 1095-C instructions require month-by-month reporting. For each full-time employee, determine:

• Whether the coverage was offered
• Who it extended to
• Whether it provided minimum value
• What the employee’s premium share was
• Whether the employee enrolled
• Whether a Section 480H safe harbor or other relief code applies

This monthly review drives what gets reported across the form’s three parts.

Form 1095-C Filing Deadlines

Form 1095-C deadline for tax year 2026 follows the standard ACA reporting calendar.

Note: The original paper filing date, February 28, 2027, falls on a Sunday, which shifts the date to the next business day.

Filers who cannot meet the electronic filing requirement may apply for a hardship waiver using Form 8508.

Alternative Furnishing Rules

Under current IRS guidance, alternative furnishing Form 1095-C rules allow ALE members to skip automatic mailing of employee statements.

Instead, the employer may post a clear, conspicuous notice on its website explaining how individuals can request a copy of their Form 1095-C.

For tax year 2026, the notice must be posted by March 2, 2027, and remain accessible through October 15, 2027. Requested copies must be provided by the later of January 31, 2027, or 30 days after the request is received.

How to Complete Form 1095-C

The core section of Form 1095-C is Part II, where ALE members have to report monthly coverage offers using 1095-C codes on lines 14, 15, and 16.

Part I — Employee and Employer Information

Enter accurate employee and ALE member details, including legal name, SSN, EIN, address, and contact number.

Part II — Employee Offer of Coverage

Enter the applicable codes on Lines 14 through 16:

• Line 14: Type of coverage offered (Code Series 1)
• Line 15: Employee’s required contribution for the lowest-cost self-only coverage providing minimum value
• Line 16: Enrollment status, relief, and affordability safe harbor codes (Code Series 2)

Important coding rules to make a note of:

• 1A: A qualifying offer was made
• 2C: Employee was enrolled for every day of the month
• 2F, 2G, 2H: Used the W-2, federal poverty line, and rate-of-pay affordability safe harbors

Part III — Covered Individuals

Complete Part III only for when the ALE member sponsors a self-insured health plan. List each enrolled individual by name, SSN (or date of birth if it’s unavailable), and the months of coverage. Use code 1G on Line 14 for nonemployees enrolled in self-insured coverage.

Common 1095-C Filing Errors to Avoid

Even experienced filers can run into issues with 1095-C employer reporting. Here are some common errors to watch for:

• Using the wrong EIN
• Missing the Authoritative Transmittal on Form 1094-C
• Entering Line 15 when it is not required
• Applying affordability safe harbor codes incorrectly
• Using code 1G for full-time employees

If a return contains a mistake, file a corrected return as soon as an error is discovered.

Form 1095-C Filing Workflow for ALE Employers

1. Confirm the ALE status using prior-year full-time and FTE data
2. Track each employee’s monthly status, coverage, waiting periods, and limited non-assessment periods.
3. Complete Lines 14, 15, and 16 codes using IRS rules and applicable affordability safe harbor rules.
4. Complete Part III for each individual enrolled in self-insured coverage and the covered months.
5. Prepare Form 1094-C and designate one Form 1094-C as the Authoritative Transmittal, when required.
6. Furnish statements directly or use the website notice method, if eligible.
7. File electronically through AIR when required and retain supporting records and confirmations.

How Form 1095-C Applies in Practice

FAQs

1. Does every employer file Form 1095-C?

No. Form 1095-C instructions apply only to ALE members, meaning employers that meet the 50-employee threshold under prior-year full-time and FTE rules.

2. What is the 2026 reporting deadline for furnishing Form 1095-C to employees?

For tax year 2026, the employee furnishing deadline for Form 1095-C is March 2, 2027.

3. Can an employer use a website notice instead of mailing Form 1095-C?

Yes, an alternative furnishing method can be used instead of mailing by posting a clear website notice and responding to employee requests.

4. When is Line 15 completed on Form 1095-C?

Line 15 reports the employee’s share of the monthly cost for the lowest-cost self-only minimum value coverage and is used only when certain Line 14 codes are used, such as 1B, 1C, 1D, or 1E.

5. What is Form 1094-C used for?

Form 1094-C is the transmittal that accompanies Forms 1095-C when filed with the IRS. If multiple Forms 1094-C are filed by the same ALE member, one of the forms must be designated as the Authoritative Transmittal.

6. Is electronic filing required for Form 1095-C?

If you are filing 10 or more information returns in aggregate for the year, then electronic filing is mandatory.