Form 1094-C: The ALE Transmittal and Summary

What Form 1094-C does

Form 1094-C is the transmittal used by an Applicable Large Employer member to accompany its Forms 1095-C. It summarizes employer information, identifies the authoritative transmittal, and reports information used by the IRS to administer the employer shared-responsibility provisions.

Who files

Each ALE member generally files its own Form 1094-C and associated Forms 1095-C. ALE status is determined by applying the federal full-time and full-time-equivalent employee rules across the prior calendar year, including applicable aggregation rules.

Electronic filing

The former 250-return threshold is obsolete. A filer generally must file electronically when it is required to file 10 or more covered information returns in aggregate during the year. A hardship waiver may be available through Form 8508.

Before filing

• Confirm ALE status and controlled-group treatment.
• Reconcile full-time employee counts and offer-of-coverage data.
• Identify the authoritative transmittal.
• Validate the total number of Forms 1095-C.
• Use the ACA Information Returns system when electronic filing is required.

This resource is provided for general educational purposes and does not constitute legal, tax, benefits, or other professional advice. Requirements and individual circumstances vary. Confirm current rules with authoritative sources and qualified advisors.