ACA Reporting for Employers: Forms 1094-C and 1095-C for the 2026 Tax Year

Who Must File Forms 1094-C and 1095-C?

Every applicable large employer (ALE) member files. For tax year 2026, that is a business that averaged 50 or more full-time employees, including full-time equivalents, during 2025. Each company in a related group files its own forms.

• Form 1095-C: one for each employee who was full-time for at least one month of 2026.
• Form 1094-C: the transmittal that summarizes the company’s forms and its monthly employee counts.
• Self-insured plans: also report everyone covered, in Part III, including enrolled part-time employees.

Not sure if you are an ALE? Run the test in our guide to applicable large employer rules and 4980H penalties.

When Are the 2026 Forms Due?

Furnish Form 1095-C to employees by March 2, 2027. File Forms 1094-C and 1095-C with the IRS by March 1, 2027 on paper, or by March 31, 2027 if you file electronically.

You must file electronically if you file 10 or more information returns in the year, counted together across most return types. Forms W-2 and 1099 count toward the 10, so almost every ALE e-files through the IRS AIR system. Form 8809 gives an automatic 30-day extension to file, but not to furnish.

What Changed Under the 2024 Reporting Laws?

Two laws signed December 23, 2024, the Paperwork Burden Reduction Act and the Employer Reporting Improvement Act, made ACA reporting easier. They allow 1095-C forms on request, more time to answer IRS penalty letters, and a 6-year limit on 4980H penalties.

• Furnish on request. In place of sending every 1095-C, post a clear, conspicuous and accessible notice on your website by the furnishing due date. Include an email address, a mailing address and a phone number, and keep the notice up through October 15 of the next year. Send a form by January 31 or within 30 days of a request, whichever is later.
• Electronic delivery. An employee who once gave affirmative consent to electronic statements is treated as still consenting, unless they revoke it in writing.
• Date of birth. If you cannot get a covered person’s taxpayer ID number, you may report their full name and date of birth.
• 90 days to answer Letter 226-J. The IRS must give you at least 90 days from its first letter proposing a 4980H penalty. It used to be 30.
• 6-year limit. The IRS must assess a 4980H penalty within 6 years of the 1094-C filing due date, or the date you filed, if later.

The website option covers the federal rule only. Some states have their own health coverage reporting rules, so check them before you stop mailing forms.

What Are the Penalties for Late or Wrong Forms?

For forms due in 2027, the penalty is $340 per return not filed correctly with the IRS and $340 per statement not furnished correctly to an employee. One missing 1095-C can cost both: $680 per employee.

• Fast corrections cost less: $60 per form if fixed within 30 days, $130 if fixed later but by August 1.
• Intentional disregard: at least $690 per form, with no annual cap.
• Annual cap: $4,191,500 per penalty type for larger businesses; lower caps apply if average gross receipts are $5 million or less.
• Reasonable cause: the IRS can waive penalties if the failure was due to reasonable cause and not willful neglect.

These reporting penalties are separate from 4980H penalties. The IRS uses your 1094-C and 1095-C data to decide whether to send a Letter 226-J, so wrong codes can cause a penalty letter you do not owe.

What Do Lines 14, 15 and 16 Show?

Line 14 shows what coverage you offered the employee each month. Line 15 shows the employee’s monthly cost for the lowest-cost self-only plan. Line 16 explains why no 4980H penalty should apply for that month, such as enrollment or an affordability safe harbor.

ACA Reporting Checklist for Tax Year 2026

• Confirm your ALE status from 2025 hours, including related companies.
• Pull monthly hours, hire and termination dates, offers and enrollments for every employee.
• Confirm the lowest-cost self-only premium and which safe harbor you use.
• Decide: mail or e-deliver every 1095-C, or post the website notice by March 2, 2027.
• Check state reporting rules where you have employees.
• Review a sample of forms for code errors, then e-file by March 31, 2027.
• Calendar a 90-day response plan in case a Letter 226-J arrives.

Where Does a Section 125 Plan Fit?

ACA reporting is about the health coverage you offer. A Section 125 plan is about how benefits are paid, with pre-tax dollars that lower payroll taxes. The two work side by side.

Our Section 125 program is for employers with 50 or more employees, so most of the businesses that use it also deal with ACA reporting. It works alongside your existing health insurance and does not replace it. A minimum essential coverage (MEC) policy is available on request; see our compliance page. Most employers save $650–$850 per employee per year.

Read our employer guide to Section 125 plans, see how setup works, or check the 2027 benefit limits.

Frequently Asked Questions

When is Form 1095-C due for the 2026 tax year?

Furnish it to full-time employees by March 2, 2027, or post a website notice by then and send forms on request. File with the IRS by March 1, 2027 on paper, or March 31, 2027 electronically.

Do employers still have to mail Form 1095-C?

Not if you use the alternative method: post a clear notice on your website and send a form within 30 days of any request (or by January 31, if later). Some state rules may still require copies.

Who has to file Form 1094-C?

Every applicable large employer member: a business that averaged 50 or more full-time employees, including full-time equivalents, in the prior year. Each company in a related group files its own.

What is the penalty for not filing Form 1095-C?

For forms due in 2027, $340 per return not filed with the IRS and $340 per statement not furnished to an employee. Quick corrections cost less; intentional disregard costs more.

How long do employers have to answer Letter 226-J?

At least 90 days from the date of the first letter, under the Employer Reporting Improvement Act. Before that law, employers generally had 30 days.

Sources

The rules and figures on this page come from these sources.

• Who files, deadlines, codes and penalties: IRS Instructions for Forms 1094-C and 1095-C
• Employer mandate: 26 U.S.C. § 4980H