Prefer not to do it yourself? ABY can help.
ACA reporting means coding and filing your 1094-C and 1095-C forms correctly and on deadline, with per-form penalties for mistakes. ABY can handle your ACA reporting end to end.
What
Annual IRS filing (Forms 1094-C plus 1095-C) reporting offers of minimum essential, minimum value coverage to full-time employees by month. Self-insured ALEs also report covered dependents on Part III of the 1095-C.
Who
Applicable Large Employers (ALEs): 50 or more full-time and full-time equivalent employees in the prior year. Controlled-group members file separately but disclose aggregated group information on the 1094-C. See the ALE Status Determination page.
When
1095-C to employees by early March; 1094-C/1095-C e-filed via AIR by March 31. An alternative furnishing method allows posting a notice and providing forms on request; check state rules.
Risk
Information-return penalties under IRC Sections 6721/6722 apply per form. 2026 per-form amounts: $60 (up to 30 days late), $130 (31 days through Aug 1), $340 (after Aug 1 or not filed), $680 for intentional disregard, no maximum. Coding or filing errors can also contribute to Section 4980H shared-responsibility assessments via IRS Letter 226J.
Early Mar
Furnish 1095-C
Permanent 30-day extension from Jan 31. Alternative furnishing available (post a notice; furnish on request).
Mar 31
E-file via AIR
File 1094-C/1095-C electronically. Paper (if eligible) is due the end of February.
10+
Mandatory e-file
Issuing 10 or more total information returns of any type requires electronic filing.
| Item | Coverage Year | Due Date | Notes |
|---|---|---|---|
| Furnish Form 1095-C to employees | 2024 coverage | March 3, 2025 | Permanent 30-day extension from Jan 31. Alternative furnishing available (post a notice; furnish on request). Check state rules. |
| File 1094-C/1095-C via AIR | 2024 coverage | March 31, 2025 | E-file required if filing 10+ information returns total; paper due Feb 28 if under threshold. |
| Furnish Form 1095-C to employees | 2025 coverage | March 2, 2026 | Same permanent extension; alternative furnishing may be used. Verify current state rules. |
| File 1094-C/1095-C via AIR | 2025 coverage | March 31, 2026 | Standard e-filing deadline. |
Item: Furnish 1095-C (2024 coverage)
Due: March 3, 2025
Notes: Permanent 30-day extension from Jan 31. Alternative furnishing available.
Item: File 1094-C/1095-C via AIR (2024 coverage)
Due: March 31, 2025
Notes: E-file if 10+ returns total; paper due Feb 28 if under threshold.
Item: Furnish 1095-C (2025 coverage)
Due: March 2, 2026
Notes: Same permanent extension; alternative furnishing may be used.
Item: File 1094-C/1095-C via AIR (2025 coverage)
Due: March 31, 2026
Notes: Standard e-filing deadline.
Paper filing: If under the 10-return e-file threshold, paper 1094-C/1095-C is due February 28 (or next business day).
- Employee roster with SSNs/TINs, monthly full-time status, and hire/termination/COBRA/leave dates.
- Monthly offer codes for Lines 14 and 16, including applicable safe-harbor and relief codes; see the Forms & Code Reference section below for a full code lookup table. Affordability inputs (W-2 wages, rate of pay, or FPL method) and employee-only premium amounts. See the Affordability Calculation page.
- Dependent coverage months for self-insured plans (Part III of the 1095-C).
- Company EIN, contact information, and controlled-group member details for the 1094-C transmittal.
- If filing in-house via AIR: Transmitter Control Code (TCC), ACA-certified software, and your test/production submission process.
1
Confirm ALE statusAnd controlled-group membership for the reporting year. See the ALE Status Determination page.
2
Choose your filing pathACA vendor/HRIS or in-house via IRS AIR.
3
Map coverage by monthCode each employee's Lines 14 and 16; validate affordability calculations and safe-harbor elections.
4
Generate and review formsSurface missing SSNs/TINs, zero-cost months, and coverage gaps before submitting.
5
Furnish 1095-CBy early March, or post the alternative-furnishing notice and provide forms promptly upon employee request.
6
E-file via AIRBy March 31; retrieve acknowledgment files and resubmit any rejected records before the deadline.
7
Correct as neededIssue corrected 1095-C forms and update your AIR submission; document what changed and when.
- Employee statements (1095-C): Mail or electronic (with prior written consent), or use the alternative furnishing method: post a clear online notice and provide the form within the required timeframe upon request. State mandates may still require automatic furnishing regardless of this option.
- Mandatory e-file: If you issue 10 or more total information returns of any type (W-2, 1099, 1095, etc.) for the year, you must file electronically. Use the IRS AIR system specifically for ACA forms.
- Corrections: Issue a corrected 1095-C and update your AIR submission; retain all correction records and submission acknowledgments.
- Furnished formsCopies or PDFs of all furnished 1095-Cs and the signed 1094-C transmittal.
- Furnishing logsMail dates, electronic-consent records, delivery confirmations, or, for alternative furnishing, the website notice and all employee request/response records.
- AIR acknowledgmentsAccepted / Accepted with Errors statuses, transmission IDs, and any error logs.
- Affordability calculationsAnd safe-harbor election documentation for each employee and plan year.
- Correction recordsCorrected 1095-C copies, updated AIR submission receipts, and notes on what was corrected and when.
Common traps
Wrong Line 14/16 codes: Using the wrong offer code (e.g., 1A when 1E applies, or omitting a safe-harbor code on Line 16) can trigger erroneous Section 4980H assessments. Map codes carefully and validate before submitting; don't assume your payroll vendor has them right without reviewing. See the code tables in the Forms & Code Reference section below.
Not retrieving AIR acknowledgments: A "Transmitted" status does not mean accepted. You must retrieve and review the acknowledgment file. Rejected records must be corrected and resubmitted before the deadline or penalties apply as if the forms were never filed.
Incorrect COBRA and leave-of-absence coding: Coding differs for offers made during active employment vs. post-employment COBRA months vs. approved leave periods. Verify the correct Line 14/16 codes for each scenario before generating forms.
FAQs
Is January 31 still the furnishing deadline?
No, there is a permanent 30-day automatic extension from January 31. Target early March for furnishing, and March 31 for the AIR e-file.
Do we have to e-file?
Yes, if you issue a combined total of 10 or more information returns of any type (W-2, 1099, 1095, etc.) for the year. Use the IRS AIR system specifically for ACA forms.
We're fully insured, do we complete Part III (covered individuals)?
No. For fully insured plans, the insurance carrier files 1095-B forms covering enrolled individuals. Only self-insured ALEs complete Part III of the 1095-C with dependent coverage details.
Do we have to report to our state separately?
Possibly. Several states have their own individual-mandate reporting requirements; see Special Cases below and the State Individual Mandate Reporting page.
- IRS: About Form 1095-C
- IRS: Instructions for Forms 1094-C & 1095-C (current)
- IRS: ACA Information Returns (AIR) Program
- IRS: Information Return Penalties (current per-form amounts and annual indexing)
- Controlled groups: Each ALE member files its own 1094-C and 1095-C forms and also discloses aggregated group information on Part II of the 1094-C. Coordinate across entities for consistent coding and to confirm each entity's separate ALE status.
- COBRA and leave of absence: Coding for post-employment COBRA months and approved leave-of-absence periods differs from active-employment months. Vendor logic helps; if filing in-house, review the IRS instructions for the applicable Line 14/16 codes before generating forms.
- Section 4980H assessments (Letter 226J): Coding or filing errors can contribute to IRS shared-responsibility payment assessments. If you receive a Letter 226J, respond within the stated deadline with documentation of offers made and safe harbors elected. Keep your 1095-C records, affordability calculations, and correction history readily accessible.
- State individual-mandate reporting: California, the District of Columbia, Massachusetts, New Jersey, and Rhode Island currently have their own individual-mandate reporting requirements with separate filing portals, formats, and deadlines. If you have employees in any of these states, check the applicable state agency for current requirements; these are separate from the federal AIR filing. See the State Individual Mandate Reporting page.
The official forms you need to file, plus a plain-English lookup table for every Line 14 and Line 16 code, so you can verify your vendor's output or code manually without hunting through the IRS instructions.
Official Forms
- Form 1095-C: Employee statement (one per full-time employee)
- Form 1094-C: Transmittal cover sheet filed with the IRS
- Instructions for Forms 1094-C & 1095-C: Full IRS instructions including all code definitions
Line 14, Code Series 1: Offer of Coverage
Enter one code per month indicating what type of coverage (if any) was offered to the employee. Use 1H for any month with no offer; never leave Line 14 blank.
| Code | What It Means | Notes |
|---|---|---|
| 1A | Qualifying Offer: MEC/MV to employee at or below 9.5% (adjusted) of mainland single FPL; MEC to spouse and dependents | Do not enter Line 15 for months coded 1A. Treated as meeting an affordability safe harbor by definition. |
| 1B | MEC/MV offered to employee only | Complete Line 15 (employee required contribution). |
| 1C | MEC/MV to employee; MEC to dependents (not spouse) | Complete Line 15. |
| 1D | MEC/MV to employee; MEC to spouse (not dependents), unconditional spousal offer only | Use 1J instead if the spousal offer is conditional (e.g., spouse not eligible elsewhere). Complete Line 15. |
| 1E | MEC/MV to employee; MEC to spouse and dependents, unconditional spousal offer only | Most common code for traditional family coverage. Use 1K if spousal offer is conditional. Complete Line 15. |
| 1F | MEC offered but does NOT provide minimum value, to employee, or employee plus family | Coverage fails the 60% minimum value test. No Section 4980H(b) safe harbor available with this code. |
| 1G | Coverage offered (any month) to a non-full-time employee enrolled in self-insured coverage | Used for part-time/variable-hour employees enrolled in a self-insured plan. Must apply to all 12 months or not at all; enter in "All 12 Months" box. |
| 1H | No offer of coverage | Default for months with no offer. Also use for COBRA months after termination and post-employment offers. Never leave Line 14 blank. |
| 1J | MEC/MV to employee; MEC conditionally offered to spouse; no dependents | Use when spousal coverage is conditioned on spouse not being eligible elsewhere. Complete Line 15. |
| 1K | MEC/MV to employee; MEC to dependents; MEC conditionally offered to spouse | Full family offer but with a conditional spousal provision. Complete Line 15. |
Line 14, ICHRA Codes (Individual Coverage HRA Offers)
Use these codes only if your organization offers an Individual Coverage HRA (ICHRA) instead of traditional group health coverage. See the ICHRA page.
| Code | Offered To | Affordability Method |
|---|---|---|
| 1L | Employee only | Employee's primary residence ZIP code |
| 1M | Employee and dependents (not spouse) | Employee's primary residence ZIP code |
| 1N | Employee, spouse, and dependents | Employee's primary residence ZIP code |
| 1O | Employee only | Work location ZIP code safe harbor |
| 1P | Employee and dependents (not spouse) | Work location ZIP code safe harbor |
| 1Q | Employee, spouse, and dependents | Work location ZIP code safe harbor |
| 1T | Employee and spouse (not dependents) | Employee's primary residence ZIP code |
| 1U | Employee and spouse (not dependents) | Work location ZIP code safe harbor |
Line 16, Code Series 2: Section 4980H Safe Harbors & Other Relief
Line 16 provides context that protects the employer from Section 4980H assessments. If an employee is enrolled in coverage, use 2C; it takes priority over most other codes. Leave blank if no code applies.
| Code | What It Means | When to Use |
|---|---|---|
| 2A | Employee not employed during the month | Employee had no hours of service on any day of the month. Do not use for the termination month itself. |
| 2B | Employee not a full-time employee for the month | Also use for the termination month when coverage ended before the last day of the month solely due to termination. |
| 2C | Employee enrolled in coverage offered | Use whenever the employee was enrolled for every day of the month. Takes priority over 2F/2G/2H. Do not use for COBRA months after termination. |
| 2D | Employee in a Section 4980H(b) Limited Non-Assessment Period | Use during initial measurement periods, waiting periods, and other limited non-assessment periods. Takes priority over 2B during measurement periods. |
| 2E | Multiemployer interim rule relief applies | Use when required to contribute to a multiemployer plan for the employee. Takes priority over all other Series 2 codes including 2C. |
| 2F | Section 4980H affordability, W-2 safe harbor | If elected, must apply for all months of the year the employee was offered coverage. Cannot be mixed with 2G or 2H for the same employee. |
| 2G | Section 4980H affordability, federal poverty line safe harbor | May be used for any month(s); does not need to be consistent across the full year. |
| 2H | Section 4980H affordability, rate of pay safe harbor | May be used for any month(s); does not need to be consistent across the full year. |