ACA Compliance
IRS Reporting Requirements
Applicable Large Employers must file annual reports with the IRS confirming that they offered qualifying coverage to eligible employees. These forms, 1094-C and 1095-C, are due each year and must be provided to employees by a specified date. Errors or missed filings can trigger IRS inquiries and penalty assessments.
Coverage Principle
IRS Reporting Requirements should be reviewed against real exposure, not assumed from the coverage label.
The real issue is not whether the coverage exists; it is whether the limits, exclusions, eligibility rules, definitions, contracts, people, property, timing, and carrier requirements match how the risk actually shows up. When those details are not reviewed before renewal or enrollment, a policy can look complete on paper while the most important conditions remain unclear until someone tries to use it.
ACA Compliance
What You Need to Know About IRS Reporting Requirements
Form 1095-C
The 1095-C is provided to each full-time employee and reports the coverage offered, the employee's share of the lowest-cost monthly premium, and the months coverage was available. Employees use it to verify they had coverage and may need it for their tax filing.
Form 1094-C
The 1094-C is the transmittal form filed with the IRS summarizing the employer's coverage offer across all employees. It's filed along with all 1095-Cs and must accurately reflect the employer's ALE status and coverage offer for the reporting year.
Deadlines and Penalties
Forms must be furnished to employees by January 31 and filed with the IRS by February 28 (paper) or March 31 (electronic). Late or incorrect filings carry per-form penalties that can accumulate quickly for employers with large workforces.