What Is Form 1095-C? Everything You Need To Know

Form 1095-C is an IRS information return that applicable large employers (ALEs) use to report the health coverage they offered to each full-time employee during the calendar year. Every full-time employee of an ALE receives the form, plus any part-time employee who is enrolled in a self-insured plan. The employer files the form with the IRS alongside Form 1094-C, the transmittal form that summarizes the included information.

In this guide, you’ll find details about the information reported on Form 1095-C and who must file, as well as associated deadlines, penalties, and common questions.

What Is Form 1095-C Used For?

Form 1095-C (Employer-Provided Health Insurance Offer and Coverage) reports information about the type of health insurance offered to applicable employees. As of 2015, ALEs must complete this tax form to remain in compliance with the Affordable Care Act (ACA). All full-time employees must receive this informational form regardless of whether they participate in the company health plan. Part-time employees will receive the form only if the company is self-insured and they enroll in the company-sponsored health plan.

The IRS uses Form 1095-C to enforce the employer shared responsibility provisions of the ACA (the "employer mandate"). It also verifies individual eligibility for premium tax credits on the Marketplace.

Who Must File or Issue Form 1095-C?

Your ALE status is determined each year by the size of your workforce in the previous calendar year, so check it annually. You qualify as an ALE if you meet the 50-employee threshold, either as a single employer or as part of a related group:

• As a single employer: You employed an average of at least 50 full-time employees, including full-time equivalents (FTEs).
• As part of a related group: You belong to a controlled group or affiliated service group whose combined workforce averaged at least 50 full-time employees, including FTEs.

If you qualify as an ALE, you must file Form 1095-C for:

• Each full-time employee. Anyone who was full-time for at least one month of the calendar year, whether or not you offered them health coverage.
• Anyone enrolled in your self-insured plan. Every enrolled individual, including part-time employees and non-employees such as retirees and COBRA participants (non-employees may be reported on Form 1095-B instead).

Note that full-time means an average of 30 or more hours a week (or 130 hours a month). To count full-time equivalents, add up the monthly hours worked by part-time employees — but do not include more than 120 hours of service per employee — and divide by 120.

When you submit your 1095-C forms to the IRS, include Form 1094-C, the transmittal form that summarizes your organization’s ALE information and coverage offers.

Form 1095-C vs. Form 1095-A vs. Form 1095-B

All three versions of Form 1095 report health coverage information to the IRS and to individuals, but they’re issued by different entities for different reasons. Knowing the difference between Forms 1095-A, 1095-B, and 1095-C helps you understand your own reporting obligations and answer employees’ questions about the forms they receive.

Here’s a quick breakdown:

If you’re a fully insured ALE, meaning your group health insurance is provided through an insurance carrier, your employees may receive both forms. You file Form 1095-C to report your offer of coverage, while your insurance carrier sends Form 1095-B to report the coverage itself.

Employees don’t need either Form 1095-B or 1095-C to file their individual tax returns. Only Form 1095-A is required for filing, because Marketplace enrollees use it to reconcile their premium tax credits.

What's Included in Form 1095-C?

The 1095-C form includes information about an employer's health care plans, the cost of coverage, and the months coverage was offered. It is divided into three parts.

Part I: Employee and Employer Information

The first part of the form reports information about the employee on lines 1-6, including their name, Social Security Number, and address. Lines 7-13 report information about the employer, including their address, a contact phone number, and an Employer Identification Number (EIN). Note that an EIN must be used to complete this form.

Part II: Employee Offer of Coverage

This section provides details about the health care plans offered each month. Employers enter the month their plan year begins and, if the employee receiving the form was offered a custom health option and individual care expense (CHOICE) arrangement the employee’s age as of January 1. Note that CHOICE coverage is alternatively known as individual coverage health reimbursement arrangement, or ICHRA.

Lines 14 and 16 use a series of codes to report the coverage offered each month and safe harbor and relief exceptions. Line 15 reports the employee’s monthly cost for the lowest-priced self-only coverage that meets minimum value, which the IRS uses to assess affordability.

Offer-of-Coverage Codes: Line 14

On line 14, enter the correct code to describe the coverage offered each month. “MEC” means minimum essential coverage, and “minimum value” means the plan covers at least 60% of expected costs.

• 1A: Qualifying offer: affordable, minimum-value coverage to the employee, plus MEC to the spouse and dependents
• 1B: Minimum-value coverage offered to the employee only
• 1C: Minimum-value coverage to the employee, plus MEC to dependents (not spouse)
• 1D: Minimum-value coverage to the employee, plus MEC to the spouse (not dependents)
• 1E: Minimum-value coverage to the employee, plus MEC to both spouse and dependents
• 1F: MEC that doesn’t provide minimum value, offered to the employee (with or without family)
• 1G: Coverage offered to a non-employee or non-full-time employee who enrolled in self-insured coverage (applies to the full year)
• 1H: No offer of coverage, or coverage offered wasn’t MEC
• 1I: This code is reserved by the IRS and not currently in use.
• 1J: Minimum-value coverage to the employee, plus MEC conditionally offered to the spouse; no dependent coverage
• 1K: Minimum-value coverage to the employee, plus MEC to dependents and conditionally to the spouse
• 1L: CHOICE, also known as ICHRA, to the employee only, with affordability based on home ZIP code
• 1M: CHOICE to the employee and dependents (not spouse), based on home ZIP code
• 1N: CHOICE to the employee, spouse and dependents, based on home ZIP code
• 1O: CHOICE to the employee only, using the work-site ZIP code safe harbor
• 1P: CHOICE to the employee and dependents (not spouse), using the work-site ZIP code safe harbor
• 1Q: CHOICE to the employee, spouse and dependents, using the work-site ZIP code safe harbor
• 1R: CHOICE that isn’t affordable, offered to the employee (with or without family)
• 1S: CHOICE offered to someone who wasn’t a full-time employee
• 1T: CHOICE to the employee and spouse (not dependents), based on home ZIP code
• 1U: CHOICE to the employee and spouse (not dependents), using the work-site ZIP code safe harbor

Safe Harbor and Other Relief Codes: Line 16

These codes explain why the employer shouldn’t owe a penalty for that employee in a given month. Enter only one code per month, and leave the line blank if none applies.

• 2A: Employee wasn’t employed on any day of the month
• 2B: Employee wasn’t full-time that month, or coverage ended mid-month because employment ended
• 2C: Employee was enrolled in the coverage offered for the entire month
• 2D: Employee was in a limited non-assessment period, such as a waiting period or initial measurement period
• 2E: Multiemployer (union) plan relief applies
• 2F: Employer used the Form W-2 wages affordability safe harbor
• 2G: Employer used the federal poverty line affordability safe harbor
• 2H: Employer used the rate-of-pay affordability safe harbor

Part III: Covered Individuals (Self-Insured Plans Only)

The last section of the form lists each person enrolled in coverage through the employee, including the employee, their spouse and their dependents. It reports each individual’s name, Social Security number or other taxpayer identification number (or date of birth if no TIN is available), and the months they were covered.

Complete this section only if you sponsor a self-insured health plan. Fully insured ALEs leave Part III blank, because their insurance carrier reports enrollment on Form 1095-B.

Who Receives a Form 1095-C?

You must provide a copy of Form 1095-C to each employee who was full-time for at least one month of the calendar year, and to any part-time employee enrolled in your self-insured plan. You can distribute it directly or post a clear notice on your website that copies are available on request.

This includes:

• Full-time employees who enroll in the company’s health care plan
• Full-time employees who were offered coverage but declined it
• Full-time employees who were not offered coverage
• Part-time employees enrolled in a self-insured company health care plan

Part-time employees who do not participate in the plan do not need to receive this form. For non-employees enrolled in a self-insured plan, such as retirees, non-employee directors or former employees who left in a prior year, ALEs may use either Form 1095-C or Form 1095-B.

How and When Do Employees Receive Form 1095-C?

Employers must furnish Form 1095-C to employees for the previous calendar year’s coverage. The IRS has permanently extended the original January 31 due date by 30 days, so for calendar year 2026, ALEs must provide Forms 1095-C to applicable employees by March 2, 2027. Employers using the alternative method must post their notice of availability on their website by the same date.

Note that only the employee receives the form. If a covered family member needs a copy, the employee must provide it.

When Must ALEs File Form 1095-C With the IRS?

The general deadline for filing paper Forms 1094-C and 1095-C with the IRS is February 28, or March 31 if filing electronically. If a due date falls on a weekend or legal holiday, it moves to the next business day.

For the 2026 calendar year, that means paper forms are due March 1, 2027, because February 28, 2027, falls on a Sunday.

Electronically filed forms are due March 31, 2027.

Keep in mind that Forms 1094-C and 1095-C are information returns, separate from filing your business tax return. They follow their own deadlines, so don’t wait until you prepare your income tax return to complete them.

All employers that file a combined total of 10 or more information returns, including Forms 1094-C and 1095-C, must file the forms electronically.

Do Any States Require Separate 1095-C Filing?

Several states have their own individual health coverage mandates and require employers to report coverage information to the state in addition to the IRS. Requirements apply based on where employees live, so even one employee residing in these jurisdictions can trigger a filing obligation. Deadlines below are for the 2026 coverage year:

• California: File with the Franchise Tax Board (FTB) by March 31, 2027. Statements to individuals are expected by January 31 (or the next business day if January 31 falls on a weekend). The FTB generally doesn’t penalize filings received by May 31. If an insurer files with the FTB for covered employees, the employer offering the coverage doesn’t have to.
• New Jersey: File with the New Jersey Division of Taxation by March 31, 2027. Employees must receive forms by March 2, 2027, in line with the federal deadline.
• Rhode Island: File with the Rhode Island Division of Taxation by March 31, 2027, and furnish forms to employees by March 2, 2027. Submissions go through the state’s individual mandate reporting portal.
• District of Columbia: File with the Office of Tax and Revenue through MyTax.DC.gov by April 30, 2027. The deadline is 30 days after the IRS deadline, including any IRS extensions, and furnishing federal Forms 1095-B or 1095-C to employees satisfies the District’s statement requirement.
• Massachusetts: Massachusetts uses its own Form MA 1099-HC rather than Form 1095-C. Employers or their carriers must distribute it to covered residents and report it electronically to the Department of Revenue by January 31 (February 1 for 2027, since January 31 falls on a Sunday).

Requirements and deadlines can change from year to year, so check each state agency’s website for current specifics. State filing doesn’t replace federal filing, and ALEs with employees in these jurisdictions must do both.

Penalties for Failing To File or Furnish Form 1095-C

Employers face two separate penalty categories tied to Form 1095-C: information reporting penalties for filing or furnishing errors, and employer shared responsibility payments (ESRP) for failing to offer compliant coverage.

Information Reporting Penalties (Sections 6721 and 6722)

Two parallel penalties apply to each form. Section 6721 penalizes failing to file a correct return with the IRS, and Section 6722 penalizes failing to furnish a correct copy to the employee. Because the same defective Form 1095-C can trigger both, a single error can double your exposure per return.

For 2026 tax year returns filed in 2027:

• Base Penalty: $340 per return under each section, with an annual cap of $4,191,500 per section for employers with average annual gross receipts over $5 million ($1,397,000 for smaller employers).
• Corrected within 30 days of the due date: $60 per return.
• Corrected after 30 days but by August 1, 2027: $130 per return.
• Intentional Disregard: At least $690 per return, with no annual cap.

The IRS proposes these penalties through Letter 972CG.

Employer Shared Responsibility Payments (Section 4980H)

ALEs face ESRP exposure when they fail to offer compliant coverage. The IRS uses Form 1094-C and 1095-C data to assess these payments. Both penalties apply only if at least one full-time employee receives a premium tax credit for Marketplace coverage.

• 4980H(a) “no coverage” penalty: Applies when an ALE fails to offer minimum essential coverage to at least 95% of full-time employees and their dependents. For 2026, it’s $3,340 per full-time employee per year, excluding the first 30 employees.
• 4980H(b) “inadequate coverage” penalty: Applies when the coverage offered is unaffordable or doesn’t provide minimum value. For 2026, it’s $5,010 per year for each full-time employee who receives a premium tax credit. This penalty can’t exceed what the employer would have owed under 4980H(a).

The IRS notifies employers of a proposed ESRP through Letter 226-J. Under the Employer Reporting Improvement Act, employers now have at least 90 days to respond, up from 30. The law also set a six-year statute of limitations on ESRP assessments.

Reducing Penalty Exposure When Filing Form 1095-C

Most Form 1095-C penalties can be reduced or avoided entirely if you act quickly and keep good records. Add these steps to your ESR reporting checklist to help limit your exposure:

• File corrected forms within 30 days of the original due date to qualify for the lowest penalty tier.
• Document reasonable-cause circumstances in writing in case of delays or errors outside your control.
• Respond to Letter 226-J or Letter 972CG within the stated window, with supporting evidence on coverage offers, affordability calculations and safe harbor codes.