ACA Form 1094-C and 1095-C filing deadlines
Applicable Large Employers report offers of coverage for the 2025 calendar year on Forms 1094-C and 1095-C in early 2026. Employee statements are due March 2, 2026; IRS electronic filing is due March 31, 2026. Two December 2024 laws changed how the statements can be furnished and how the IRS can assess penalties. This guide covers who files, the dates, the penalties, and what changed.
Who has to file?
Applicable Large Employers (ALEs) file. An ALE is an employer that averaged 50 or more full-time employees, including full-time equivalents, during the prior calendar year, so 2025 reporting turns on the 2024 headcount. Companies under common ownership are aggregated to test the threshold; each EIN then files its own Form 1094-C and set of 1095-Cs.
An ALE furnishes a Form 1095-C to every employee who was full-time for at least one month of the year. An ALE with a self-insured plan also furnishes one (Part III completed) to every other enrolled individual: part-time employees, COBRA participants, retirees.
Employers under 50 FTEs that sponsor a self-insured plan (including level-funded arrangements) are not ALEs but still report minimum essential coverage under IRC §6055 on Forms 1094-B and 1095-B. Fully insured small employers have no form to file; the carrier reports on the 1095-B.
A sponsor's funding arrangement and enrolled headcount are on its Form 5500 record in the employer index.
What are the 2026 deadlines?
Three dates matter for the 2025 coverage year. All three are fixed by regulation or statute and do not require an extension request.
- March 2, 2026 — furnish Form 1095-C to employees. The statutory date is January 31. The December 2022 final rule (T.D. 9970) added a permanent, automatic 30-day extension. Thirty days after January 31 is March 2 in a non-leap year such as 2026 (March 1 in a leap year). No request is needed.
- March 2, 2026 — paper filing with the IRS. The paper due date is February 28, which falls on a Saturday in 2026 and rolls to Monday, March 2. Almost no ALE can file on paper anymore (see below).
- March 31, 2026 — electronic filing with the IRS through the ACA Information Returns (AIR) system. An automatic 30-day extension is available by filing Form 8809 on or before March 31; it extends the IRS filing date only, not the furnishing date.
E-filing is mandatory at 10 returns. Under T.D. 9972 (February 2023), the threshold dropped from 250 to 10 returns, counted across all information-return types the filer issues (W-2, 1099, 1095, and others). Every ALE exceeds 10; paper filing is left to very small self-insured employers filing 1095-Bs.
Month-by-month timeline for the 2026 season
| When | What | Owner |
|---|---|---|
| Nov–Dec 2025 | Lock measurement-period results; confirm 2025 ALE status from the 2024 headcount; confirm the vendor will produce 2025-year forms. | HR / payroll |
| Early Jan 2026 | Reconcile enrollment, hire and termination dates, and monthly offers against payroll. Decide on the alternative furnishing method and draft the notice. | HR / benefits |
| Late Jan 2026 | Generate draft 1095-Cs; sample-check line 14/16 codes for new hires, terminations, leaves, and COBRA enrollees. | Benefits / vendor |
| Mar 2, 2026 | Furnish 1095-Cs (mail, electronic with consent, or the posted notice). Paper IRS filing due the same day for the few still eligible. | Employer |
| Mar 31, 2026 | Electronic filing through AIR; keep the receipt ID and acceptance status. File Form 8809 by this date for a 30-day extension. | Employer / vendor |
| Apr–Jul 2026 | Work AIR error files and TIN mismatches; corrections filed by August 1 carry the lower penalty tier. | Employer / vendor |
| Oct 15, 2026 | Earliest date the alternative-method website notice may come down. Requested 2025 forms are due by the later of January 31, 2026 or 30 days after the request, so after January 31 it is simply 30 days. | HR |
What did the Paperwork Burden Reduction Act change?
The Paperwork Burden Reduction Act (H.R. 3797, signed December 23, 2024) lets an employer stop mailing Forms 1095-C and instead furnish them on request, provided it posts a notice. IRS Notice 2025-15 (February 2025) borrowed the existing 1095-B rules at Treas. Reg. §1.6055-1(g)(4)(ii)(B). The conditions:
- Post a clear and conspicuous notice on the employer's website, in a location reasonably accessible to every person who would otherwise receive a form. The IRS example is a “Tax Information” link on the home page leading to a page with an email address, a physical address, and a phone number.
- Post it by the furnishing deadline (March 2, 2026 for 2025 forms) and keep it up through October 15, 2026.
- Furnish any requested form by the later of January 31 of the following year or 30 days after the request (P.L. 118-167); once January 31 has passed, that means 30 days.
The method changes nothing about the IRS filing; Forms 1094-C and 1095-C still go to the IRS by March 31. States with individual-mandate reporting (California, New Jersey, Rhode Island, Massachusetts, and the District of Columbia) have their own furnishing rules.
What did the Employer Reporting Improvement Act change?
The companion law (H.R. 3801, also signed December 23, 2024) made three procedural changes, effective for returns due after December 31, 2024:
- Name and date of birth in place of a TIN. Where a covered individual's taxpayer identification number is not available, the form may show full name and date of birth. This was IRS practice for the 1095-B; it is now statute for both the 1095-B and 1095-C.
- At least 90 days to respond to Letter 226-J. The IRS must give an ALE at least 90 days to answer the first letter proposing an employer shared-responsibility payment under IRC §4980H. The prior practice was 30 days.
- Six-year assessment window. The IRS has six years from the return due date (or filing date, if later) to assess a §4980H payment. Before the Act there was no clear limit, because the payment is not reported on a return.
For the affordability side of the §4980H calculation, see ACA affordability for 2026.
Penalties for 2025 forms filed in 2026 — $340 per form, charged twice
IRS information-return penalties under IRC §6721 (filing) and §6722 (furnishing) are indexed each year. For returns and statements due in 2026 (the 2025 coverage year), the IRS penalty table shows: $60 per form if corrected within 30 days of the due date; $130 if corrected by August 1; $340 if filed after August 1 or not at all; and $680 for intentional disregard, with no cap. (The 2025-due amounts were $60 / $130 / $330 / $660.)
A single late or wrong 1095-C can be penalized under both sections, so the practical exposure is $680 per employee statement. The annual caps for the $340 tier are $4,098,500 for employers with gross receipts above $5 million and $1,366,000 below it (Rev. Proc. 2024-40). Reasonable-cause waivers remain available; good-faith relief for incorrect information ended with the 2020 forms.
Line 14 and line 16 codes, in brief
Line 14 says what was offered each month; line 16 says why no §4980H penalty applies. The common codes:
- 1A — qualifying offer: minimum value coverage at an employee-only cost within the federal poverty line safe harbor, plus minimum essential coverage to spouse and dependents. Line 16 stays blank with 1A.
- 1E — minimum value coverage offered to the employee, spouse, and dependents, but not a qualifying offer (the common code for most full-time employees). Pair with a line 16 safe harbor: 2C (employee enrolled), 2F (W-2 safe harbor), 2G (federal poverty line), or 2H (rate of pay).
- 1H — no offer of coverage. Pair with 2A (not employed that month), 2B (not full-time), or 2D (limited non-assessment period, such as a new hire's waiting period).
- 1L through 1S — individual coverage HRA (ICHRA) offers, with a ZIP code on line 17.
The error behind most Letter 226-Js is a blank line 16 for a month in which an employee waived coverage: the IRS reads a blank as no safe harbor and proposes a Penalty B if that employee bought subsidized exchange coverage.
What to do next
- Confirm your 2025 ALE status from the 2024 monthly headcount, and list every EIN in the controlled group that needs its own 1094-C.
- Decide by mid-January whether to use the alternative furnishing method; if yes, have the website notice drafted and ready to post by March 2, 2026, and keep it up through October 15, 2026.
- Confirm in writing which party (payroll vendor, ACA vendor, or the employer) transmits through AIR by March 31, 2026 and keeps the receipt ID.
- Sample-audit line 14/16 codes for new hires, terminations, leaves, and waivers before transmitting.
- Keep offers, safe-harbor calculations, and enrollment records for six years from the filing date, matching the new assessment window.
Sources
- IRS — Instructions for Forms 1094-C and 1095-C (2025) — Who files, when to furnish and file, line 14/16 codes, and the alternative manner of furnishing.
- IRS — Information return penalties (amounts by year due) — Per-return amounts for returns due in 2026: $60 / $130 / $340 / $680.
- IRS Notice 2025-15 — Alternative manner of furnishing Forms 1095-B and 1095-C — February 2025 guidance implementing the Paperwork Burden Reduction Act notice-posting method.
- Federal Register — Information Reporting of Health Insurance Coverage and Other Issues (T.D. 9970, Dec. 15, 2022) — The final rule that made the 30-day furnishing extension permanent and automatic.
- Federal Register — Electronic-Filing Requirements for Specified Returns (T.D. 9972, Feb. 23, 2023) — Lowered the e-filing threshold to 10 aggregated information returns, effective for returns due in 2024 and later.
- Congress.gov — H.R. 3801, Employer Reporting Improvement Act (Public Law 118-168) — TIN/date-of-birth substitution, 90-day Letter 226-J response window, six-year assessment window.