What Is Form 1094-C?

Form 1094-C is a transmittal form used by Applicable Large Employers (ALEs) to report information about health coverage offered to employees under the Affordable Care Act (ACA). It serves as a cover sheet submitted to the Internal Revenue Service (IRS) along with Form 1095-C filings. This form is essential for demonstrating an employer’s compliance with the ACA’s employer shared responsibility provisions.

Purpose of Form 1094-C

The primary purpose of Form 1094-C is to summarize and transmit the information provided on Form 1095-C. While Form 1095-C is distributed to individual employees and filed with the IRS to detail health coverage for each person, Form 1094-C aggregates that data at the employer level. It acts as a declaration that the employer has complied with the requirements to offer minimum essential coverage that is affordable and provides minimum value to full-time employees.

It is also used by the IRS to determine whether an employer may be subject to a shared responsibility payment (penalty) for failing to offer appropriate health coverage.

Who Must File Form 1094-C

Only employers defined as Applicable Large Employers are required to file Form 1094-C. An ALE is an employer that had an average of 50 or more full-time employees (including full-time equivalents) during the previous calendar year. These employers are subject to the ACA’s Employer Mandate, which requires offering health coverage to at least 95% of full-time employees and their dependents.

Each ALE member (a separate legal entity, even within a controlled group) must file its own Form 1094-C, even if the group as a whole meets the ALE threshold.

Key Components of Form 1094-C

Form 1094-C consists of several parts, each serving a distinct reporting purpose:

Part I – Employer Information
This section collects basic identifying information, including the employer's name, Employer Identification Number (EIN), address, and contact details for the person responsible for the filing.

Part II – ALE Member Information
This section includes information that establishes the scope and nature of the employer’s ACA compliance:

• Whether the form is the authoritative transmittal for the employer (only one authoritative transmittal is filed per ALE member).
• The total number of Forms 1095-C being submitted with this transmittal.
• A checkbox indicating whether the employer is part of an Aggregated ALE Group.
• The full-time employee count for each month of the year.
• Total employee count per month, whether full-time or not.

Part III – Certifications of Eligibility
This section provides checkboxes that allow employers to indicate if they qualify for transition relief or other simplified reporting options under the ACA, such as the 98% Offer Method or the Section 4980H Transition Relief.

Part IV – Aggregated ALE Group Members
If the employer is part of a controlled group or affiliated service group (as defined by IRS rules), this section is used to list other ALE members in the group. This part supports IRS efforts to enforce shared responsibility provisions across related companies.

Filing Requirements and Deadlines

Form 1094-C is typically filed with the IRS along with copies of all Form 1095-C documents issued to employees. Employers must file electronically if they are submitting 10 or more forms. The IRS imposes penalties for failing to file on time, failing to file electronically when required, or submitting incorrect or incomplete information.

Filing deadlines generally fall in the first quarter of the year following the calendar year being reported. For example, for the 2024 calendar year, the Form 1094-C filing deadline would likely fall in March 2025 (if filing on paper) or later in March (if filing electronically). Deadlines may shift slightly year to year.

Common Mistakes to Avoid

While Form 1094-C is a summary, mistakes can lead to compliance issues or IRS penalties. Common errors include:

• Incorrectly stating the number of 1095-C forms filed.
• Not designating one submission as the “authoritative transmittal.”
• Misreporting full-time employee counts.
• Failing to include other members of a controlled group when applicable.

Employers are encouraged to use reputable ACA compliance software or consult with tax and benefits professionals to ensure accuracy.

How It Interacts with Form 1095-C

Form 1095-C is completed for each full-time employee and includes detailed information about the health coverage offered (or not offered) each month. Form 1094-C, by contrast, does not contain individual employee details but instead summarizes the total number of 1095-C forms submitted and reports on the employer’s overall coverage strategy and compliance status.

The IRS uses the two forms together to assess whether an employer satisfied the ACA’s coverage obligations and whether any penalties may apply.

The Bottom Line

Form 1094-C is a crucial IRS filing for large employers under the ACA. It acts as a cover sheet for the more detailed Form 1095-C and provides the IRS with key information about the employer’s compliance with health coverage mandates. Failing to file accurately and on time can result in significant penalties. For employers, especially those with complex organizational structures or variable workforces, ensuring proper filing of Form 1094-C requires careful recordkeeping and often, expert guidance.