ACA Forms › Form 1094-C (2026): ALE Instructions & Filing Deadlines
At a Glance
Form 1094-C is the transmittal form that accompanies Form 1095-C when Applicable Large Employers (ALEs) file with the IRS. It summarizes employer health coverage information and is only submitted to the IRS, not provided to employees. Learn what data is required, authoritative transmittal rules, filing deadlines, and penalties.
The ACA provision mandates that employers provide their employees with affordable healthcare. In line with this, Sections 6055 and 6056 of the ACA state that Applicable Large Employers (ALEs) must submit 1094-C and 1095-C forms to the IRS by the deadline.
Ultimately, ALEs use the 1094-C and 1095-C forms to report the employee health insurance information offers to the IRS.
What is Form 1094-C?
Form 1094-C serves is the Transmittal of Employer-Sponsored Health Insurance Offer and Coverage Information Returns Form, accompanying Form 1095-C in annual IRS filings.
Form 1094-C is essentially a summary of the 1095-C information returns. This form is only submitted to the IRS and not given to the employees.
What is Form 1095-C?
Form 1095-C is an information return filed by employers with at least 50 full-time + full-time equivalent employees. These employers are known as 'Applicable Large Employers' or ALEs by the IRS. This form tells the IRS if the employer met ACA guidelines for the healthcare coverage they offer, and it requires that employees receive a recipient copy.
Applicable Large Employers
at least 50 full-time + full-time equivalent employees for all EINs added together that share a common owner
Learn more about what Form 1095-C is for Tax Year 2025.
We also recommend checking out the IRS.gov ACA FAQ, which contains many common 1095-C questions in an easy-to-understand format.
What is the deadline to submit ACA Form 1094-C?
Here are the critical dates for filing and distributing Form 1094-C deadlines.
March 2nd, 2026
Paper File Deadline
March 2nd, 2026
Employee Copy Deadline
March 31st, 2026
E-File Deadline
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Details needed to complete Form 1094-C?
The following information is required for Form 1094-C:
- Employer information (Name, EIN, contact info, address)
- Total number of Forms 1095-C submitted with the Form 1094-C
- Aggregate ALE information (if applicable)
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What is an Authoritative Transmittal Form 1094-C?
If an ALE member submits multiple 1094-C forms, only one must be declared the authoritative transmittal on Part I, line 19.
The Authoritative Transmittal should comprise the combined data of all full-time and part-time employees.
Filing Form 1094-C Electronically for the 2025 Tax Year
Submitting your 1094-C electronically takes just a few minutes with our platform. Our user-friendly process and built-in audit checks catch common errors before your returns reach the IRS.
Import Your Form 1094-C Data
You can import your data as Excel, XML, or use files from popular payroll providers like QuickBooks, UKG, ADP, and many more.
Step-By-Step Wizard
We walk you through the process with no complicated jargon. You can also live chat with a real person as you work on your filing for hands-on help.
E-File & Mail Employee Copies
Once your data is loaded, you can e-file and distribute employee copies in minutes.
How Do You File ACA Forms Online?
Generally, ACA filing is handled by self-filing or by using an ACA Software provider:
- Simple format for data import (like Excel)
- Can often use your payroll files directly
- No testing, TCC, or IRS account required
- Can help with questions/coding
Self-Filing
- Format requires custom software development
- Filing system can be slow and unreliable
- Requires testing, TCC, and personal info
- Errors and issues reported can be cryptic
Learn more about filing ACA Forms online.
What are the types of Form 1095 Penalties?
ACA penalties are typically split into two categories:
-
Employer Shared Responsibility Payment (ESRP):
This penalty applies to large employers who do not offer minimum essential coverage to at least 95% of their full-time employees (and their dependents),
and at least one of their full-time employees receives a premium tax credit for purchasing individual coverage on one of the health insurance marketplaces.
The ESRP is also known as the "employer mandate" or "play or pay" penalty.
- Reporting and Disclosure Penalties: These penalties are assessed for failing to file required information returns with the IRS or to provide required statements to individuals. These information returns include Form 1094-C and Form 1095-C, which large employers must file under the ACA's reporting requirements.
For more information about the various types of IRS ACA penalties and their corresponding fines, visit our penalty guide.
What are the penalties for not submitting ACA Forms 1095-B & 1095-C?
The IRS determines ACA penalties based on various factors, including missing the deadline, providing incorrect information, or using paper forms when electronic filing is required.
The IRS has increased the penalty amounts for the 2026 filing year.
Failure to file ACA 1095 Forms 2026
$340 per form
up to$1,366,000 per year (smaller businesses)
$4,098,500 per year
Failure to furnish ACA 1095 Forms 2026
$340 per form
up to$1,366,000 per year (smaller businesses)
$4,098,500 per year
Intentionally not filing for 2026
$680 per form
no maximum penalty
Author
Michaela Porterfield
Content Writer at BoomTax
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Dedicated to simplifying complex IRS regulations for employers, with expertise in ACA, 1099, and W-2 compliance.
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BoomTax and its affiliates do not provide tax, legal, or accounting advice. This material has been prepared for informational purposes only, and is not intended to provide, and should not be relied on for, tax, legal, or accounting advice. You should consult your own tax, legal, and accounting advisors prior to engaging in any transaction.
