When is the filing deadline for forms 1094-C and 1095-C?

For the 2020 filing year, Applicable Large Employers (ALEs) must provide Forms 1095-C to employees by March 2, 2021. ALEs must submit Forms 1095-C, along with Form 1094-C, to the IRS by February 28, 2021 (if filed by mail) or March 31, 2021 (if filed electronically).

Note: Employers that are required to file 250 or more 1095-C Forms must file electronically. However, the IRS encourages employers to file electronically even if they are filing fewer than 250 returns.
For more information visit this IRS page. https://www.irs.gov/affordable-care-act/questions-and-answers-about-health-care-information-forms-for-individuals. All forms and instructions may also be found on the IRS website

Form 1095-C is filed and furnished to any employee of an ALE member who is a full-time employee for one or more months of the calendar. ALE Members must report that information for all twelve months of the calendar year for each employee.

The 1094-C is the transmittal form that must be filed with the Form 1095-C.

Form 1095-B is used to report certain information to the IRS and to taxpayers about individuals who are covered by minimum essential coverage and therefore are not liable for the individual shared responsibility payment.

The 1094-B is the transmittal form that must be filed with the Form 1095-B.

The employer files 1094-C and 1095-C to report the information under sections 6055 and 6056. The 1094-C will be used to report the summary information for each employer and to transmit 1095-C to the IRS. The two forms are also used to determine whether the employer owes a payment under the employer shared responsibility provisions under section 4980H.

Employers who offer an employer-sponsored self-insured plan also use Form 1095-C to report information to the IRS and to employees about individuals who have minimum essential coverage under the employer plan.

The 1094-B and 1095-B is also for self-insured plans but for small groups not subject to the employer shared responsibility provisions. In addition, the health insurance issuers or carriers must file Form 1095-B for most health insurance coverage, including individual market coverage and insured coverage sponsored by employers.

Definition of Aggregated ALE Group:
An Aggregated ALE Group is a group of ALE Members (employers) treated as a single employer for the purposes of 1095 filing. Companies with a common owner or are otherwise related are considered part of an Aggregated ALE Group.

When determining ALE status, full time employees and full time equivalents for each of the members of the Aggregated ALE Group are combined. Example:

  • Corporation X owns 100 percent of all classes of stock of Corporation Y and Corporation Z.
  • Corporation X has no employees at any time in 2015.
  • For every calendar month in 2015, Corporation Y has 40 full-time employees and Corporation Z has 60 full-time employees. Neither Corporation Y nor Corporation Z has any full-time equivalent employees.
  • Corporations X, Y, and Z are considered a controlled group of corporations.
  • Because Corporations X, Y and Z have a combined total of 100 full-time employees for each month during 2015, Corporations X, Y, and Z together are an ALE for 2016.
  • Corporation Y and Z are each an ALE member for 2016.
  • Corporation X is not an ALE member for 2016 because it does not have any employees during 2015.


Each member of an Aggregated ALE group is liable for filing 1095 forms for their employees. In the above example, 1095-C forms will be filed for the employees who worked for Corporations Y and Z. In addition, separate authoritative 1094-C forms will need to be filed for both Corporation Y and Corporation Z. Each member of an Aggregated ALE Group will need to file one authoritative 1094-C form per tax year.

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