Box 1: Name of employeeFirst name, middle initial, last name. Use the name that goes with the SSN on line 2; a name and SSN that do not match come back as TIN validation errors from AIR.Click to open the row in the table belowBox 2: Social security number (SSN)The full nine-digit SSN goes on the copy filed with the IRS. You may truncate it to the last four digits on the employee's copy only; “Truncation is not allowed on forms filed with the IRS”.Click to open the row in the table belowBox 3 to 6: Employee addressStreet, city, state and ZIP or foreign postal code. A country code is not required for U.S. addresses.Click to open the row in the table belowBox 7: Name of employerThe ALE Member's name, which should match line 1 of its Form 1094-C.Click to open the row in the table belowBox 8: Employer identification number (EIN)The ALE Member's own nine-digit EIN, never truncated and never the parent's EIN. A 1095-C without a valid EIN will not be processed.Click to open the row in the table belowBox 9: Street addressThe ALE Member's address; it should match lines 3 to 6 of the Form 1094-C.Click to open the row in the table belowBox 10: Contact telephone numberThe number an employee calls about the form. It may differ from the IRS contact on line 8 of the 1094-C, and it should reach someone who can correct errors.Click to open the row in the table belowBox 11 to 13: City, state, ZIPRest of the ALE Member's address, consistent with the 1094-C.Click to open the row in the table belowPart II: Employee's age on January 1 and Plan Start MonthAge is entered only if an individual coverage HRA was offered. Plan Start Month is mandatory: “This box is required for the 2026 Form 1095-C and the ALE Member may not leave it blank”; enter 01 to 12, or 00 if no plan offered coverage.Click to open the row in the table belowBox 14: Offer of CoverageOne Code Series 1 code per month, or one code in All 12 Months. “Do not leave line 14 blank for any month”, including months the person was not employed (use 1H). An offer counts for a month only if coverage would run every day of that month.Click to open the row in the table belowBox 15: Employee Required ContributionThe employee share of the monthly cost of the lowest-cost self-only minimum value coverage offered, not what the employee actually pays. Complete it only for codes 1B, 1C, 1D, 1E, 1J, 1K, 1L to 1Q, 1T and 1U; enter 0.00 for a free plan rather than leaving it blank.Click to open the row in the table belowBox 16: Section 4980H Safe Harbor and Other ReliefAt most one Code Series 2 code per month (2A to 2H; 2I is reserved), or blank if none applies. 2C (enrolled) generally wins over any other code; there is no code for a full-time employee who declined.Click to open the row in the table belowBox 17: ZIP codeOnly for individual coverage HRA codes: the residence ZIP (1L, 1M, 1N, 1T) or the primary work site ZIP under the location safe harbor (1O, 1P, 1Q, 1U).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.
Who files Form 1095-C
Every ALE Member files a Form 1095-C for each employee who was a full-time employee for any month of the calendar year. An ALE is an employer, or an Aggregated ALE Group under common control, that averaged at least 50 full-time employees (including full-time equivalent employees) on business days in the preceding calendar year. Full-time means the section 4980H definition: an average of at least 30 hours of service per week, with 130 hours in a month treated as the monthly equivalent. Each member of an aggregated group files under its own EIN “even if the ALE Member has fewer than 50 full-time employees of its own”.
An ALE Member that sponsors a self-insured plan (including an individual coverage HRA) also files a 1095-C, Parts I, II and III, for any employee who enrolled, full-time or not. Non-full-time enrollees get code 1G on line 14 for all 12 months. Nonemployee enrollees (retirees from a prior year, COBRA beneficiaries who left in a prior year, nonemployee directors) may be reported on a 1095-C with code 1G or on Form 1095-B instead.
An employer that self-insures but is not an ALE does not file Form 1095-C; it files Form 1095-B. If the plan is insured, the insurer reports enrollment on Form 1095-B and the ALE leaves Part III blank.
Box by box
| Box | What it is | Notes |
|---|---|---|
| 1 | Name of employee | First name, middle initial, last name. Use the name that goes with the SSN on line 2; a name and SSN that do not match come back as TIN validation errors from AIR. |
| 2 | Social security number (SSN) | The full nine-digit SSN goes on the copy filed with the IRS. You may truncate it to the last four digits on the employee's copy only; “Truncation is not allowed on forms filed with the IRS”. |
| 3 to 6 | Employee address | Street, city, state and ZIP or foreign postal code. A country code is not required for U.S. addresses. |
| 7 | Name of employer | The ALE Member's name, which should match line 1 of its Form 1094-C. |
| 8 | Employer identification number (EIN) | The ALE Member's own nine-digit EIN, never truncated and never the parent's EIN. A 1095-C without a valid EIN will not be processed. |
| 9 | Street address | The ALE Member's address; it should match lines 3 to 6 of the Form 1094-C. |
| 10 | Contact telephone number | The number an employee calls about the form. It may differ from the IRS contact on line 8 of the 1094-C, and it should reach someone who can correct errors. |
| 11 to 13 | City, state, ZIP | Rest of the ALE Member's address, consistent with the 1094-C. |
| Part II | Employee's age on January 1 and Plan Start Month | Age is entered only if an individual coverage HRA was offered. Plan Start Month is mandatory: “This box is required for the 2026 Form 1095-C and the ALE Member may not leave it blank”; enter 01 to 12, or 00 if no plan offered coverage. |
| 14 | Offer of Coverage | One Code Series 1 code per month, or one code in All 12 Months. “Do not leave line 14 blank for any month”, including months the person was not employed (use 1H). An offer counts for a month only if coverage would run every day of that month. |
| 15 | Employee Required Contribution | The employee share of the monthly cost of the lowest-cost self-only minimum value coverage offered, not what the employee actually pays. Complete it only for codes 1B, 1C, 1D, 1E, 1J, 1K, 1L to 1Q, 1T and 1U; enter 0.00 for a free plan rather than leaving it blank. |
| 16 | Section 4980H Safe Harbor and Other Relief | At most one Code Series 2 code per month (2A to 2H; 2I is reserved), or blank if none applies. 2C (enrolled) generally wins over any other code; there is no code for a full-time employee who declined. |
| 17 | ZIP code | Only for individual coverage HRA codes: the residence ZIP (1L, 1M, 1N, 1T) or the primary work site ZIP under the location safe harbor (1O, 1P, 1Q, 1U). |
| 18 to 30 | Part III: Covered Individuals | Self-insured coverage only; check the Part III box. Columns (a) name, (b) SSN or other TIN, (c) date of birth (YYYY-MM-DD) only if (b) is blank, (d) covered all 12 months, (e) months covered for at least one day. Use extra copies of page 3 for more than 13 people. |
Due dates
| What | Due | Notes |
|---|---|---|
| Furnish Form 1095-C to full-time employees (2026) | March 2, 2027 | The January 31 date is automatically extended to March 2, 2027; no further extension is granted. |
| Alternative manner: post the website notice | March 2, 2027 | Keep it in the same place through October 15, 2027, and send a requested statement within 30 days of the request. |
| File with the IRS on paper (fewer than 10 returns in aggregate) | March 1, 2027 | February 28, 2027 is a Sunday, so the instructions give March 1. |
| File with the IRS electronically through AIR | March 31, 2027 | Form 8809 filed by the due date gives an automatic 30-day extension of the filing date only. |
| Replace a rejected AIR transmission | Within 60 days | A replacement accepted within 60 days of the rejected status is treated as filed on the original date (Pub 5165, section 7.3). |
| Keep copies | 3 years | From the due date of the returns, or keep the ability to reconstruct the data. |
Penalties
Forms 1094-C and 1095-C are information returns, so the general information reporting penalties apply: IRC 6721 for failing to file a correct return and IRC 6722 for failing to furnish a correct statement to the employee. For 2026 returns due in 2027 the tiers are $60 per return if corrected within 30 days, $130 if corrected by August 1, $340 after that or never, and $690 for intentional disregard (Rev. Proc. 2025-32). The 2026 draft instructions put the full-rate penalty at $340 per return and $340 per statement, each capped at $4,191,500 a year, with higher amounts and no cap for intentional disregard. The 6722 penalty may be imposed in addition to the 6721 penalty for the same form.
Failing to e-file when required costs $340 per return unless you show reasonable cause, but up to 10 returns may be filed on paper without that penalty. Penalties can be waived for reasonable cause under section 6724 and Treas. Reg. 301.6724-1; for Part III, Treas. Reg. 1.6055-1(h) also applies.
Separately, the data on these forms is what the IRS uses to decide whether the employer owes an employer shared responsibility payment under section 4980H. A wrong code on line 14 or 16, or a missing return, can create a section 4980H problem that is far larger than the reporting penalty. For the IRS inquiry about returns it thinks are missing, see our guide to Letter 5699.
Corrections
To correct a 1095-C already filed with the IRS, file a fully completed new 1095-C with the CORRECTED box checked, send it with a non-authoritative Form 1094-C (do not check CORRECTED on that 1094-C), and furnish the employee a corrected copy. If the form was furnished but never filed, write “CORRECTED” on the new employee copy and do not check the box. Electronically, corrections go through AIR as a correction transmission that references the Unique Record ID of the accepted record; corrections are allowed only for transmissions that were Accepted, Accepted with Errors or Partially Accepted. A rejected transmission is not corrected, it is replaced.
Line 15 has a de minimis safe harbor (Notice 2017-9): if no single amount is off by more than $100, you generally need not correct to avoid penalties, unless the employee elects out of the safe harbor. You are also not required to file corrected returns for missing or incorrect TINs if you meet the reasonable cause criteria in Pub 1586.
If the employer used the Qualifying Offer alternative statement, it must send a corrected statement when it corrects the employer name, EIN, address or contact on the filed 1095-C, and must send a full 1095-C if the employee no longer qualifies for the alternative.
Where it goes wrong
- Blank months on line 14. Every month needs a code. Former employees still get 1H plus 2A for the months after they left; the month of termination is never 2A.
- COBRA reported as an offer. An offer of COBRA after termination of employment is reported as 1H with 2A, whether or not the person enrolled; only COBRA offered to someone still employed is an offer on line 14.
- Safe harbor codes in the wrong months. A 2F, 2G or 2H code should not be entered for any month where the 1094-C, Part III, column (a) says No. Code 2F, if used, must be used for every month the employee was offered coverage.
- Two forms for one employee. Two divisions under one EIN must combine into a single 1095-C. Two ALE Members in a group each file their own, with only one treated as the employer for any month.
- Part III filled in for an insured plan. Part III is for self-insured coverage only; the insurer reports insured coverage on Form 1095-B.
- Name and SSN mismatches. AIR returns an Error Data File that can include TIN validation errors. For covered individuals in Part III, a TIN solicitation to the employee counts for everyone on the coverage, and a date of birth may be entered when no TIN is available. See solicitation rules for how the initial and annual solicitations work.
Inside the IRS: what happens to Form 1095-C
Form 1095-C is the data behind the Employer Shared Responsibility Payment (ESRP). IRM 8.7.21 explains that SB/SE “issues Letter 226-J, ESRP Preliminary Contact, to certain ALEs” when, for at least one month, a full-time employee “was enrolled in a qualified health plan for which a PTC was allowed” and no affordability safe harbor or other relief applied. The IRM says the determination and the amount in the letter “are based on information from Forms 1094-C and 1095-C filed by the ALE and the individual income tax returns filed by the ALE’s employees.” The case file lists those employees on Form 14765, Employee Premium Tax Credit (PTC) Listing.
An ALE that disagrees after the IRS responds with Letter 227-L or 227-M “can request a pre-assessment Appeals conference”. An assessed ESRP posts to its own account (MFT 43), separate from the information return penalties.
Paper Forms 1095-C are scanned under IRM 3.41.267. A batch is unprocessable when “50 percent or more of the TINs (social security numbers (SSNs)) show only the last four-digits of the SSNs (appear redacted)”, or when the employer EIN on Form 1094-C “does not match the employer listed on Form 1095-C”. Employee copies mailed to the IRS on their own are not processed: for a loose Form 1095-C the campus routing guide says “Destroy locally as classified waste.”
Late, missing or incorrect forms draw IRC 6721 and 6722 penalties. TIN errors are excused if the employer followed the solicitation rules: filers “will not be subject to penalties for failure to report a TIN” when they meet Treas. Reg. 301.6724-1(e) or (f). For penalties assessed for not filing, field collection employees are told to “advise the taxpayer or authorized representative to file before an abatement request is considered.”
What to do: check lines 14 to 16 for every full-time employee before filing, since the Letter 226-J calculation is built from them, and keep the records behind each code ready for a Letter 226-J reply.
Notices about this form
Questions people ask about Form 1095-C
Do we still have to mail every employee a 1095-C?
Not necessarily. Under the Paperwork Burden Reduction Act (Pub. L. 118-167) and Notice 2025-15, an ALE may instead post a clear and conspicuous website notice that employees may request their statement, with an email address, mailing address and phone number. For 2026 the notice must be posted by March 2, 2027 and kept up through October 15, 2027, and a requested copy must be furnished by the “later of January 31 of the year following the calendar year for which the return was required to be made or 30 days after the date of the request”. You still file every 1095-C with the IRS.
Are there any new codes for 2026?
No. The 2026 draft instructions carry the same series as 2025: line 14 codes 1A to 1H and 1J to 1U (1I and 1V to 1Z reserved), and line 16 codes 2A to 2H (2I reserved). The affordability percentage used for the Qualifying Offer and the safe harbors is 9.96% for plan years beginning in 2026.
Did ACA filing move to IRIS?
No. For 2026 returns filed in 2027, Forms 1094-B, 1095-B, 1094-C and 1095-C are e-filed through the ACA Information Returns (AIR) system with an ACA Transmitter Control Code; Pub 5165 for processing year 2027 is the AIR guide. A FIRE or IRIS TCC cannot be used for AIR.
We have 30 employees on 1095-Cs but file 1099s too. Do we have to e-file?
If the total of all your information returns (1095-Cs, 1099s, W-2s and others) is 10 or more, yes. The 10-return test is applied in the aggregate, so a filer may have fewer than 10 Forms 1094-C and 1095-C and still be required to e-file. A hardship waiver (Form 8508) is the exception.
An employee has no SSN on file. Can we leave line 2 blank?
Line 2 calls for the employee's SSN. Form 1095-C may be used only if the individual on line 1 has an SSN; for covered family members in Part III you may enter another TIN, or a date of birth if there is none. Keep records of your TIN solicitations: penalty relief for missing or incorrect TINs depends on them.
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: 1094-C · 1095-B · 1094-B
Paper transmittal: 1096
These forms on the comparison table · Information returns (1099 series)
Sources: Form 1095-C (2026); Instructions for Forms 1094-C and 1095-C (2026 draft dated Sept. 4, 2026; 2025 final for comparison); Notice 2025-15; Pub 5165 (Rev. 9-2026), Guide for Electronically Filing ACA Information Returns; IRS AIR program page and E-file information returns page (Oct. 2026); Pub 1586 (Rev. 8-2026); IRC 6056, 6055, 4980H, 6721, 6722, 6724; Rev. Proc. 2025-32.