When people refer to "IRS Form 1094," they’re not talking about a single document. Instead, Form 1094 is a category of transmittal forms—specifically, Form 1094-B and Form 1094-C—used to report compliance with the Affordable Care Act (ACA). These forms are submitted to the IRS along with Forms 1095-B or 1095-C, providing summary information that verifies whether individuals or employees were offered minimum essential coverage.
Understanding the differences between these two forms and who must file each is essential to avoiding penalties and maintaining ACA compliance. If you're unsure which version applies to your business or how to file correctly, explore the 1095EZ Advantage — a turn-key ACA compliance solution designed to simplify Form 1094 and 1095 filings. Our platform operates independently of your back-office systems and helps ensure accuracy, reduce administrative burden, and protect your business from costly IRS penalties.
What Is IRS Form 1094?
IRS Form 1094 is not filed on its own. Instead, it serves as a cover sheet or transmittal form that accompanies either:
- Form 1095-B, which reports individual-level health coverage details, or
- Form 1095-C, which reports employer-sponsored health insurance for full-time employees.
Form 1094 is used to summarize the accompanying 1095 forms and provide the IRS with aggregate data related to health coverage. Required under the ACA, these forms help ensure that individuals and employers meet healthcare coverage mandates.
Form 1094-C Overview
Form 1094-C is required for Applicable Large Employers (ALEs) — businesses with 50 or more full-time or full-time equivalent employees. It acts as the transmittal form for all Forms 1095-C, which are provided to each eligible employee.
What It Reports
Form 1094-C provides summary-level data that includes:
- The employer's contact details
- EIN
- Number of 1095-C forms filed
- Monthly full-time employee counts
- Confirmation of minimum essential coverage offered
- Whether the employer was part of an Aggregated ALE Group
Deadlines
- Paper filing: February 28
- Electronic filing: March 31 (required if filing 10 or more forms)
- Furnishing 1095-C to employees: Typically March 2
Penalties
Failure to file accurate or timely 1094-C and 1095-C forms can result in penalties of up to $330 per form, with higher amounts for intentional disregard.
Form 1094-B Overview
Form 1094-B is used by entities that provide minimum essential coverage, such as:
- Insurance carriers
- Small self-insured employers (typically with fewer than 50 full-time employees)
- Government programs such as Medicaid
It transmits Forms 1095-B, which report health coverage provided to individuals and their dependents.
What It Reports
This form includes:
- Name and contact information of the reporting entity
- Total number of 1095-B forms submitted
- Issuer-specific details relevant to the filing year
Deadlines
- Paper filing: February 28
- Electronic filing: March 31
- Furnishing 1095-B to recipients: Typically March 2
Penalties
Just like Form 1094-C, failure to file or furnish accurate 1094-B/1095-B forms may result in penalties of up to $330 per form.
Key Differences Between 1094-B and 1094-C
| Feature | Form 1094-B | Form 1094-C |
|---|---|---|
| Who Files | Insurance providers, small self-insured employers | Applicable Large Employers (50+ FTEs) |
| Paired With | Form 1095-B | Form 1095-C |
| Reports | Coverage for individuals and dependents | Summary of employer coverage offers to employees |
| Common Use | Small groups or insurers | Mid- to large-size employers |
Common Filing Mistakes to Avoid
To stay compliant and avoid fines, watch out for these common mistakes:
1. Mixing up 1094-B and 1094-C
Always file the correct form based on your organization's size and the type of health coverage provided.
2. Missing deadlines
Late filings can result in substantial penalties. Be sure to track all IRS deadlines for both forms and their corresponding 1095s.
3. Inconsistent data between forms
Ensure employee counts and coverage details match between 1094 and 1095 filings to avoid IRS scrutiny.
4. Incomplete reporting
Review all sections for completeness, including eligibility certifications and Aggregated ALE Group information, if applicable.
Wrap-Up: Get the Right Form 1094 Filed with Confidence
While Form 1094 is not filed on its own, it plays a critical role in ACA compliance. Whether you’re an insurance provider, a small business, or an ALE, understanding which version of Form 1094 applies to you—and filing it accurately—is essential.
Not sure which form to file or how to get started? Discover the 1095EZ Advantage — a simple, turn-key solution that streamlines your ACA compliance reporting and works independently of your back-office software. Stay compliant, reduce administrative burden, and file confidently with better, faster, and more affordable support from 1095EZ Online.