ACA Forms Understanding IRS Form 1094-C 2023

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The ACA provision mandates that employers provide their employees with affordable healthcare. In line with this, Sections 6055 and 6056 of the ACA state that Applicable Large Employers (ALEs) must submit 1094-C and 1095-C forms to the IRS by the deadline.

Ultimately, ALEs use the 1094-C and 1095-C forms to report the employee health insurance information offers to the IRS.

What is Form 1094-C?

Form 1094-C serves is the Transmittal of Employer-Sponsored Health Insurance Offer and Coverage Information Returns Form, accompanying Form 1095-C in annual IRS filings.

Form 1094-C is essentially a summary of the 1095-C information returns. This form is only submitted to the IRS and not given to the employees.

What is Form 1095-C?

Form 1095-C is an information return filed by employers with at least 50 full-time + full-time equivalent employees. These employers are known as 'Applicable Large Employers' or ALEs by the IRS. This form tells the IRS if the employer met ACA guidelines for the healthcare coverage they offer, and it requires that employees receive a recipient copy.

Applicable Large Employers

at least 50 full-time + full-time equivalent employees for all EINs added together that share a common owner

For more info on Tax Year 2022 Form 1095-C, click here

We also recommend checking out the ACA FAQ, which contains many common 1095-C questions in an easy-to-understand format.

What is the deadline to submit ACA Form 1094-C?

Here are the critical dates for filing and distributing Form 1094-C deadlines.

February 28th, 2023

Paper File Deadline

March 2nd, 2023

Employee Copy Deadline

March 31st, 2023

E-File Deadline

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Details needed to complete Form 1094-C?

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The following information is required for Form 1094-C:

  • Employer information (Name, EIN, contact info, address)
  • Total number of Forms 1095-C submitted with the Form 1094-C
  • Aggregate ALE information (if applicable)

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What is an Authoritative Transmittal Form 1094-C?

If an ALE member submits multiple 1094-C forms, only one must be declared the authoritative transmittal on Part I, line 19.

The Authoritative Transmittal should comprise the combined data of all full-time and part-time employees.

Filing Form 1094-C Electronically for the 2022 Tax Year

takes just a few minutes with our platform. Our user-friendly process and built-in audit checks ensure that your returns are error-free when sent to the IRS.

Import Your Form 1094-C Data

You can import your data as Excel, XML, or use files from popular payroll providers like QuickBooks, UKG, ADP, and many more.

Step-By-Step Wizard

We walk you through the process with no complicated jargon. You can also chat with us as you work on your filing for hands-on help.

E-File & Mail Employee Copies

Once your data is loaded, you can e-file and distribute employee copies in minutes.

How Do You File ACA Forms Online?

Generally, ACA filing is handled by self-filing or by using an ACA Software provider:

small boomtax logo

  • Simple format for data import (like Excel)
  • Can often use your payroll files directly
  • No testing, TCC, or IRS account required
  • Can help with questions/coding


  • Format requires custom software development
  • Filing system can be slow and unreliable
  • Requires testing, TCC, and personal info
  • Errors and issues reported can be cryptic

Learn more about filing ACA Forms online.

What are the Form 1095 Penalties?

ACA penalties are typically split into two categories:

  1. Employer Shared Responsibility Payment (ESRP): This penalty applies to large employers who do not offer minimum essential coverage to at least 95% of their full-time employees (and their dependents), and at least one of their full-time employees receives a premium tax credit for purchasing individual coverage on one of the health insurance marketplaces. The ESRP is also known as the "employer mandate" or "play or pay" penalty.

  2. Reporting and Disclosure Penalties: These penalties are assessed for failing to file required information returns with the IRS or to provide required statements to individuals. These information returns include Form 1094-C and Form 1095-C, which large employers must file under the ACA's reporting requirements.

Please click here to learn more about the various types of IRS ACA penalties and their corresponding fines.

What are the penalties for not submitting ACA Forms 1095-B & 1095-C?

The IRS determines ACA penalties based on various factors, including missing the deadline, providing incorrect information, or using paper forms when electronic filing is required.

Failure to file ACA 1095 Forms 2023

$290 per form

up to

$1,177,500 per year (smaller businesses)

$3,532,500 per year

Failure to furnish ACA 1095 Forms 2023

$290 per form

up to

$1,177,500 per year (smaller businesses)

$3,532,500 per year

Intentionally not filing for 2023

$580 per form

no maximum penalty

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