Form 1094-C vs. Form 1095-C
How the employer-level transmittal and employee-level statements work together in Applicable Large Employer reporting.
Who uses these forms
Applicable Large Employer members generally file one or more Forms 1094-C and a Form 1095-C for each employee who was full-time for at least one month. ALE status generally begins at an average of at least 50 full-time employees, including full-time-equivalent employees, in the preceding year, with controlled-group aggregation rules.
How the forms connect
Form 1094-C identifies the ALE member, transmits its Forms 1095-C, and supplies employer-level information. Form 1095-C reports the monthly employee-specific data used to administer employer shared responsibility and premium tax credit rules. Self-insured ALEs also use Part III of Form 1095-C for covered-individual information.
Current filing rules
For 2025 calendar-year reporting, the IRS deadlines were March 2, 2026 for paper filing and March 31, 2026 for electronic filing. Electronic filing is generally required when the filer must submit 10 or more covered information returns in aggregate.
Practical reconciliation
- Confirm ALE and aggregated-group status.
- Reconcile the Form 1094-C employee counts to the 1095-C population.
- Validate monthly offer and safe-harbor codes.
- Align self-insured enrollment data with covered individuals.
- Coordinate corrections across both form types.
Primary sources
This resource is provided for general educational purposes and does not constitute legal, tax, benefits, safety, or other professional advice. Requirements and individual circumstances vary. Confirm current rules with authoritative sources and qualified advisors.
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