Box 1: Name of ALE Member (Employer)The legal name of the member whose EIN is on line 2. Must match line 7 of its 1095-Cs.Click to open the row in the table belowBox 2: Employer identification number (EIN)The ALE Member's EIN, never an SSN. “If a valid EIN is not provided, Form 1094-C will not be processed.”Click to open the row in the table belowBox 3 to 6: AddressComplete address; it should match the address on the member's Forms 1095-C.Click to open the row in the table belowBox 7: Name of person to contactThe person who answers IRS questions about the filing. May differ from the employee contact on 1095-C line 10.Click to open the row in the table belowBox 8: Contact telephone numberTelephone for the line 7 contact.Click to open the row in the table belowBox 9 to 16: Designated Government EntityOnly for a DGE filing on behalf of a governmental unit: DGE name, EIN, address and contact. Leave blank otherwise.Click to open the row in the table belowBox 18: Total number of Forms 1095-C submitted with this transmittalOnly the 1095-Cs attached to this particular 1094-C. On a non-authoritative transmittal this is the only count you report.Click to open the row in the table belowBox 19: Is this the authoritative transmittal for this ALE Member?Check it on exactly one 1094-C per ALE Member and complete Parts II to IV. On any other transmittal, sign and leave Parts II, III and IV blank.Click to open the row in the table belowBox 20: Total number of Forms 1095-C filed by and/or on behalf of ALE MemberAll 1095-Cs for the member across every transmittal, including those for non-full-time enrollees in a self-insured plan.Click to open the row in the table belowBox 21: Is ALE Member a member of an Aggregated ALE Group?Yes if it was in a group for any month; then complete Part III column (d) and Part IV.Click to open the row in the table belowBox 22: Certifications of EligibilityBox A, Qualifying Offer Method; box D, 98% Offer Method; B and C are reserved. Check only if you are eligible for and using the method.Click to open the row in the table belowHover over a box for what goes in it; click to open its row in the table below. On a touch screen, tap the box to jump to the row.
Box 23: All 12 MonthsUse this row when a column's entry is the same for the whole year instead of filling the monthly rows.Click to open the row in the table belowBox 24 to 35: January to DecemberMonthly entries for columns (a) to (d) when they vary. Column (e) is reserved.Click to open the row in the table belowWho files Form 1094-C
Every ALE Member that files Forms 1095-C files at least one Form 1094-C. It may split its 1095-Cs across several transmittals (for example, one per division), but “one (and only one) Form 1094-C filed by the ALE Member must be identified on line 19, Part I, as the Authoritative Transmittal”, and that one carries the aggregate data for all of the member's employees.
Members of an Aggregated ALE Group each file separately: “Each ALE Member must file its own Forms 1094-C and 1095-C under its own separate EIN, even if the ALE Member is part of an Aggregated ALE Group”, and “No Authoritative Transmittal should be filed for an Aggregated ALE Group.” A Designated Governmental Entity (DGE) filing for a governmental unit completes lines 9 to 16; everyone else skips them.
Box by box
| Box | What it is | Notes |
|---|---|---|
| 1 | Name of ALE Member (Employer) | The legal name of the member whose EIN is on line 2. Must match line 7 of its 1095-Cs. |
| 2 | Employer identification number (EIN) | The ALE Member's EIN, never an SSN. “If a valid EIN is not provided, Form 1094-C will not be processed.” |
| 3 to 6 | Address | Complete address; it should match the address on the member's Forms 1095-C. |
| 7 | Name of person to contact | The person who answers IRS questions about the filing. May differ from the employee contact on 1095-C line 10. |
| 8 | Contact telephone number | Telephone for the line 7 contact. |
| 9 to 16 | Designated Government Entity | Only for a DGE filing on behalf of a governmental unit: DGE name, EIN, address and contact. Leave blank otherwise. |
| 18 | Total number of Forms 1095-C submitted with this transmittal | Only the 1095-Cs attached to this particular 1094-C. On a non-authoritative transmittal this is the only count you report. |
| 19 | Is this the authoritative transmittal for this ALE Member? | Check it on exactly one 1094-C per ALE Member and complete Parts II to IV. On any other transmittal, sign and leave Parts II, III and IV blank. |
| 20 | Total number of Forms 1095-C filed by and/or on behalf of ALE Member | All 1095-Cs for the member across every transmittal, including those for non-full-time enrollees in a self-insured plan. |
| 21 | Is ALE Member a member of an Aggregated ALE Group? | Yes if it was in a group for any month; then complete Part III column (d) and Part IV. |
| 22 | Certifications of Eligibility | Box A, Qualifying Offer Method; box D, 98% Offer Method; B and C are reserved. Check only if you are eligible for and using the method. |
| a | Minimum Essential Coverage Offer Indicator | Yes for each month the member offered minimum essential coverage to at least 95% of full-time employees and their dependents; employees in a Limited Non-Assessment Period are not counted. |
| b | Section 4980H Full-Time Employee Count for ALE Member | Monthly full-time count under the section 4980H definition, excluding employees in a Limited Non-Assessment Period; enter -0- for zero. Not required if box D is checked. |
| c | Total Employee Count for ALE Member | All employees, full-time or not, counted on one consistent day of each month chosen from the five options in the instructions. |
| d | Aggregated Group Indicator | X for each month the member was in an Aggregated ALE Group. |
| 23 | All 12 Months | Use this row when a column's entry is the same for the whole year instead of filling the monthly rows. |
| 24 to 35 | January to December | Monthly entries for columns (a) to (d) when they vary. Column (e) is reserved. |
| 36 to 65 | Part IV: Other ALE Members of Aggregated ALE Group | Name and EIN of up to 30 other members (not the reporting member), in descending order of average monthly full-time employees, or of total employees if any member uses the 98% Offer Method. |
Due dates
| What | Due | Notes |
|---|---|---|
| File Form 1094-C with Forms 1095-C on paper (2026) | March 1, 2027 | Allowed only below the 10-return aggregate e-file threshold or with an approved waiver. |
| File through AIR (2026) | March 31, 2027 | Form 8809 filed by the due date gives an automatic 30-day extension. |
| Furnish Forms 1095-C to employees | March 2, 2027 | The 1094-C itself is not furnished to anyone. |
| Request an e-file waiver (Form 8508) | 45 days before the due date | Encouraged timing; it must be filed no later than the due date and is not processed before January 1. |
| Correct an Authoritative Transmittal | As soon as possible | File a standalone corrected 1094-C with nothing attached. |
Penalties
The 1094-C rides with the 1095-Cs, and a missing or late filing is penalized per return under IRC 6721: for 2026 returns due in 2027, $60 within 30 days, $130 by August 1, $340 after that, and $690 for intentional disregard (Rev. Proc. 2025-32). Failing to e-file when required costs $340 per return beyond the 10 that may go on paper, unless you show reasonable cause.
The larger exposure is section 4980H. The Authoritative Transmittal's column (a) answers the 95% offer test month by month, and column (b) feeds the full-time count. An X in No for a month, or a missing Authoritative Transmittal, can turn into an employer shared responsibility assessment. For the IRS inquiry about missing Forms 1094-C and 1095-C, see our guide to Letter 5699.
Corrections
Only the Authoritative Transmittal is ever corrected. Prepare a new, fully completed 1094-C with the correct information, check CORRECTED, and file it alone: “Do not file any other documents (for example, Form 1095-C) with the corrected Authoritative Transmittal.” “Do not file a return correcting information on a Form 1094-C that is not the Authoritative Transmittal.” Typical triggers are a wrong member name or EIN, the line 20 total, aggregated group membership, the column (a) offer indicator, or the column (b) count.
When you are correcting 1095-Cs, send them with a non-authoritative 1094-C that is not marked CORRECTED. In AIR, a 1094-C correction carries the CorrectedUniqueSubmissionId of the accepted submission, and transmissions must not mix originals, corrections and replacements. A transmission or submission AIR rejected is replaced, not corrected, and a replacement received within 60 days of the rejected status keeps the original receipt date.
Where it goes wrong
- Group-level authoritative transmittal. Combined data for several members under the parent's EIN is exactly what the instructions prohibit; each member reports only its own employees on its own Authoritative Transmittal.
- Two authoritative transmittals for one EIN. When divisions file separate transmittals under one EIN, only one may check line 19, and it reports the totals for both.
- Line 18 vs line 20. Line 18 counts the forms attached to this transmittal; line 20 counts all forms for the member. On a single-transmittal filer they are the same number.
- Column (a) and line 16 out of step. If column (a) says No for a month, the 1095-Cs should not show affordability safe harbor codes for that month.
- Using a non-4980H definition of full-time (a benefits-eligibility or HR definition) for column (b).
- Transmission mechanics. AIR will not take B and C forms, or two tax years, in one transmission, and the form data file may not exceed 100 MB. Keep the Receipt ID, status and Error Data File for each submission: you need them to correct later, even if a third party transmitted.
Inside the IRS: what happens to Form 1094-C
The IRS uses Form 1094-C to know which employers are ALEs. IRM 8.7.21 describes it as “used to report summary information for each ALE Member and to transmit Forms 1095-C to the IRS”, and the Letter 226-J calculation rests on the 1094-C and 1095-C data together with employees' individual returns. Account staff check filing with “IDRS CC IRPOL with definer A”, which “shows if Form 1094-C/Form 1095-C were filed.”
Whether a 1094-C is on file changes how the IRS treats you. If an ESRP payment arrives and no 1094-C or 1095-C is on record, IRM 21.2.4 has the IRS refund it with Letter 672C, saying “we have no record that they are an Applicable Large Employer (ALE) or subject to the Employer Shared Responsibility Payment”, with a request to review the filing requirement. An employer that appears to be an ALE but did not file may instead receive “Letter 5699 Non-Filer” (see the Letter 5699 guide).
Paper submissions go into their own sort, “sorted into a separate sort for the IRP Sort Unit to release to SCRIPS for priority processing”, and scanned under IRM 3.41.267. A 1094-C sent alone is processed only as a correction to an Authoritative Transmittal, “with an entry in both corrected box (checked) and Part I, Line 19 box (checked)”. A 1094-C with no 1095-C behind it is unprocessable when “the corrected box and line 19 both do not contain a mark”, as is one whose EIN “does not match the employer listed on Form 1095-C”.
The Payer Master File keeps “five most current tax years of information” for 1094-C transmittals, which is where late filing and e-file penalties are computed. What to do: file one Authoritative Transmittal per ALE Member, keep the EIN identical on the 1094-C and every 1095-C, and correct a standalone 1094-C only with both the corrected box and line 19 checked.
Questions people ask about Form 1094-C
What happens on a 1094-C that is not the Authoritative Transmittal?
You complete Part I, enter the number of attached 1095-Cs on line 18, sign it, and leave Parts II, III and IV blank. Only the Authoritative Transmittal reports the member-level data.
What is the 98% Offer Method?
Box D on line 22. If, counting every month employees were employed and not in a Limited Non-Assessment Period, the member offered affordable minimum value coverage to at least 98% of the employees for whom it files a 1095-C (and coverage to their dependents), it may skip the full-time count in column (b). It must still file a 1095-C for every full-time employee.
Our group has 45 companies. Do we list them all in Part IV?
No. List up to 30 other members, ranked by average monthly full-time employees (or total employees if any member uses the 98% Offer Method), excluding the reporting member.
Do we need our own ACA TCC?
Only if you transmit yourself. Pub 5165 says ACA returns must be filed through AIR using an ACA Transmitter Control Code and “ACA Information Returns may not be filed using any other Transmitter Control Code”; an employer using a third party to prepare and transmit does not need one.
Can the 1094-C be filed through IRIS?
No. The IRS lists Forms 1094-B, 1095-B, 1094-C and 1095-C as filed through AIR for tax year 2026, and the IRIS Taxpayer Portal guide states that TCCs obtained for AIR “cannot be used in the IRIS Taxpayer Portal”.
Other employer, withholding and ACA forms
Payroll and employment tax returns: W-4 · 941 · 941-X · 944 · 943 · 940 · W-2 · W-3 · W-2c · 8027
Withholding returns: 945 · 1042
Health coverage (ACA) returns: 1095-C · 1095-B · 1094-B
Paper transmittal: 1096
These forms on the comparison table · Information returns (1099 series)
Sources: Form 1094-C (2026); Instructions for Forms 1094-C and 1095-C (2026 draft dated Sept. 4, 2026); Pub 5165 (Rev. 9-2026); Pub 5164 (Rev. 7-2026); Pub 5717 (Rev. 9-2026); IRS AIR program page and E-file information returns page (Oct. 2026); IRC 6056, 4980H, 6011(e), 6721; Rev. Proc. 2025-32.