What Is a Form 1094-C? Everything Employers Need to Know

Form 1094-C is a transmittal form used by Applicable Large Employers (ALEs) to report compliance with the Affordable Care Act (ACA). It summarizes health coverage information provided on Forms 1095-C, which are filed for individual employees. If you’re an ALE with 50 or more full-time equivalent employees, accurate completion of this form is not just required; it is essential to avoiding IRS penalties.

If you need hands-on help with ACA reporting, speak with an expert at 1095EZ Online to ensure your Form 1094-C is filed accurately and on time.

While the IRS website provides access to the form and its official instructions, the details can be overwhelming and unclear for many employers. That’s why this guide exists: to help simplify what the IRS often complicates.

This guide will explain everything employers need to know about Form 1094-C, including who must file, what the form includes, how to avoid common filing errors, and how platforms like 1095EZ Online can streamline your ACA compliance.

What Is Form 1094-C?

Form 1094-C is submitted to the IRS by ALEs to confirm they have offered minimum essential coverage (MEC) to eligible employees as required by the ACA. Think of it as a "cover sheet" for the more detailed employee-level Forms 1095-C.

While Form 1095-C is filed for each eligible employee, Form 1094-C gives the IRS a summary view of the employer’s total ACA compliance across the calendar year.

Who Needs to File Form 1094-C?

You must file Form 1094-C if:

• Your business qualifies as an Applicable Large Employer (ALE), meaning you had an average of 50 or more full-time equivalent (FTE) employees in the previous calendar year.
• You are filing Forms 1095-C for employees. Form 1094-C is required even if no employees received coverage or even if no penalties are due.
• Each ALE Member in an Aggregated ALE Group must file their own Form 1094-C and corresponding 1095-Cs.

Key Components of Form 1094-C

Form 1094-C is broken into four main parts:

Part I – ALE Member Information

Includes basic business details:

• Legal name, EIN, address, and contact person
• Total number of 1095-C forms filed with the IRS
• Designated Government Entity (if applicable)

Part II – ALE Member Certification

Includes checkboxes that indicate whether the ALE:

• Is part of an Aggregated ALE Group
• Used the 98% Offer Method (coverage offered to 98% of employees)
• Used the Qualifying Offer Method

Part III – Monthly Coverage Information

This section contains monthly breakdowns of:

• Whether MEC was offered to 95% of full-time employees
• Number of full-time employees by month
• Total number of employees by month
• Whether the ALE was part of an Aggregated Group that month

Part IV – Other ALE Members

If your company is part of an Aggregated ALE Group (such as multiple subsidiaries), you must list the names and EINs of the other group members here.

Filing Deadlines for Form 1094-C

IRS filing deadlines are strict. For Tax Year 2024, the deadlines are:

• Paper Filing: February 28, 2025
• Electronic Filing: March 31, 2025 (required if filing 10 or more forms)
• Employee Copy of Form 1095-C: Must be furnished by March 2, 2025

Note: If the deadline falls on a weekend or holiday, it rolls to the next business day.

How to File Form 1094-C

Filing Form 1094-C accurately is essential to stay compliant with IRS requirements. Employers can choose one of the following filing methods:

• By mail, using standard paper forms (only if submitting fewer than 10 forms total across all series)
• Electronically, through an IRS-authorized ACA software provider (required if filing 10 or more forms)

For paper submissions, forms must be:

• Printed in landscape format
• Include full unmasked Social Security Numbers on each Form 1095-C
• Mailed in a flat envelope without staples or paperclips

Common Mistakes to Avoid When Filing Form 1094-C

Filing Form 1094-C might seem straightforward, but many employers make costly mistakes that lead to penalties, delayed IRS processing, or employee confusion. Below are the most frequent errors, why they matter, and how to avoid them:

1. Misreporting Full-Time Employee Counts

Failing to correctly calculate and report your full-time employee totals can trigger inaccurate penalty assessments. Be sure to use the proper ACA formula:

Tip:
Full-Time Employees + (Total Part-Time Hours ÷ 120) = FTE Total

2. Incorrect Use of Certification Checkboxes (Part II)

Marking the wrong eligibility method (such as the 98% Offer Method or Qualifying Offer Method) without meeting IRS criteria can invalidate your filing.

3. Mismatched Data Between Form 1094-C and 1095-C

Totals reported on your 1094-C must align with the individual 1095-Cs you submit. Inconsistencies may trigger IRS inquiries or audits.

4. Missing the Authoritative Transmittal Checkbox

If filing multiple 1094-Cs, one must be marked as the “authoritative transmittal.” Missing this makes it unclear which is official.

5. Not Reporting Aggregated ALE Group Members (When Applicable)

If part of an Aggregated ALE Group, failure to list other members in Part IV can result in incorrect filings and penalties.

Penalties for Incorrect or Late Filing

Penalties can easily add up, especially for employers filing 250 or more forms.

How 1095EZ Online Simplifies Form 1094-C Filing

1095EZ Online is an all-in-one ACA compliance platform that streamlines Form 1094-C and 1095-C preparation, validation, and filing. Key benefits include:

• Seamless integration with any back-office system
• Automated validation of employee counts and offer of coverage
• Filing deadline reminders and real-time status tracking
• Affordable, scalable pricing for businesses of all sizes

Our software minimizes human error and ensures compliance with the latest IRS requirements without the paperwork headache.

Final Thoughts

Form 1094-C may be just one page, but it carries significant weight with the IRS. Filing it accurately, on time, and in alignment with Forms 1095-C is critical to staying ACA compliant and avoiding penalties.

Whether you're filing on your own or working with an aggregator, 1095EZ Online gives you peace of mind with tools that simplify every step of the process. Contact us today!