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What is Form 1094-C?

1094-C is the transmittal form that accompanies Form 1095-C when filing with the IRS each year. Together, Forms 1094-C and 1095-C are used to provide information to the IRS regarding health insurance coverage offered to your full-time employees and that status of individual employee’s enrollment. Form 1094-C is only sent to the IRS, not to employees.

Who needs to file a form 1094-C?

Applicable Large Employers (ALEs) must file one or more Forms 1094-C (including one designated as the Authoritative Transmittal, whether or not filing multiple Forms 1094-C) with the IRS when filing Form 1095-C for each employee who was a full-time employee for any month of the calendar year. Companies with 50 or more full-time employees are considered ALEs.

Form 1094-C Filing Deadline

Beginning with the 2023 tax year, employers must file Form 1094-C to the IRS with Form 1095-C. Both forms are due to the IRS by February 28th (if paper filing) or March 31st (if e-filing) of the year following the calendar year the return references. If the regular due date falls on a Saturday, Sunday, or legal holiday, you must file by the next business day.

Late Filing Penalties

Employers that do not submit Form 1094-C to the IRS may be subject to a penalty of up to $310 per missing form, with a maximum penalty of $3 million per calendar year. Waivers are available when failure to report is due to a reasonable cause. Limited relief is also available for incorrect or incomplete information reported.

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