If you are an employer defined as an Applicable Large Employer (ALE), you should begin to plan for submitting the required 1094/1095-C forms to the IRS.
- ALEs are companies who average 50 or more full-time or full-time equivalent employees (FT/FTE). This is determined each calendar year and is based on the average size of an employer’s workforce during the prior year.
- If an employer has at least 50 full-time employees, including full-time equivalent employees, on average during the prior year, the employer is an ALE for the current calendar year.
- Employers sponsoring self-insured (including level-funded) health plans have these responsibilities regardless of size.
Forms to Employees
- The 1095-C is provided by ALEs with fully insured health plans to all employees who were employed for any month of the calendar year.
- ALEs with fully insured health plans complete parts I and II of the form.
- ALEs with self-insured health plans complete the entire form.**
- The 1095-B is provided by small employers (fewer than 50 full-time equivalent employees) sponsoring self-insured health plans to all employees who were employed for any month of the calendar year.
Forms to the IRS
- The 1094-C is submitted to the IRS by ALEs with fully insured health plans along with copies of all the 1095-Cs by March 31, 2026 (or February 28, 2026, if filing on paper).
- The 1094-C is also submitted to the IRS by ALEs with self-insured health plans along with copies of all the 1095-Cs by March 31, 2026 (or February 28, 2026, if filing on paper).
- The 1094-B is submitted to the IRS by small employers sponsoring self-insured health plans along with copies of all the 1095-Bs by March 31, 2026 (or February 28, 2026, if filing on paper).
NOTE: Electronic filing is REQUIRED for those filing 10 or more information returns.
All reporting will be for the 2025 calendar year, even for non-calendar year plans.
Furnishing Forms 1095-C to Employees
An ALE must furnish a Form 1095-C, or a 1095-B if self-funded, to each of its full-time employees by March 2, 2026.
Alternative Furnishing Method
- Employees may be provided the notice electronically:
- Employers may post a clear, conspicuous notice on their website stating that employees may request a copy of their 1095-C.
- The notice must remain available through October 15, 2026.
- Employers must furnish the form within 30 days of receiving a request.