Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, is the form applicable large employers (generally 50 or more full-time employees, including full-time equivalents) use to report the health coverage they offered each full-time employee, month by month. It's filed with the IRS alongside Form 1094-C, and since the 2025 forms employers no longer have to send it to employees automatically if they offer it on request.
If your business is growing past 50 staff, Form 1095-C is one of the Affordable Care Act jobs that arrives with it. If you're an employee who got one, it's the record your employer sends to show what coverage you were offered. Here's how the IRS instructions describe it, including a furnishing change in the 2025 instructions.
Who has to file Form 1095-C
The instructions say employers with 50 or more full-time employees, including full-time equivalent employees, in the previous year use Forms 1094-C and 1095-C. That employer is an applicable large employer (ALE). A full-time employee, under the monthly measurement method, is someone employed an average of at least 30 hours of service per week in a calendar month.
- Companies under common ownership are aggregated to decide whether they're an ALE, using the rules in section 414.
- Each ALE member then files its own forms for its own full-time employees.
- ALEs must report even if they didn't offer any health coverage.
- Self-insured ALEs also report who was covered, in Part III.
What the form reports
| Part of Form 1095-C | What it shows |
|---|---|
| Part I | The employee and the ALE member |
| Line 14 | A code for the offer of coverage each month (Code Series 1) |
| Line 15 | The employee's required contribution for the lowest-cost self-only coverage |
| Line 16 | A Code Series 2 code for section 4980H safe harbors and other relief |
| Line 17 | The location safe harbor for individual coverage HRAs, if used |
| Part III | Covered individuals, for self-insured plans |
The IRS uses the information to administer the employer shared responsibility rules and the premium tax credit, and employees can use it to see whether they could claim that credit for each month.
The furnishing change in the 2025 instructions
The What's New section of the 2025 instructions says employers no longer have to send Form 1095-C to individuals automatically. The furnishing requirement is met if the employer posts a clear, conspicuous and accessible notice on its website that an individual may request a copy, and then furnishes it on time. For the 2025 forms, 'on time' means by the later of January 31, 2026, or 30 days after the request. The IRS points to Notice 2025-15 for the detail.
Older IRS pages still describe automatic furnishing to every full-time employee by January 31, so it's easy to follow out-of-date advice. If you switch to the notice method, make the notice easy to find and keep a process for answering requests within 30 days.
Deadlines for the 2025 forms
| Task | Deadline |
|---|---|
| File Forms 1094-C and 1095-C on paper | March 2, 2026 |
| File electronically | March 31, 2026 |
| Furnish to employees (or answer requests) | By the later of January 31, 2026, or 30 days after a request |
| Automatic extension to file | 30 days, using Form 8809 filed by the due date |
E-filing: the 10-return rule
The instructions say that if you're required to file 10 or more information returns during the year, you must file electronically. The threshold is 10 information returns in total, not 10 Forms 1095-C, so a business with this many staff will almost always be over it. Failing to e-file when required can bring a penalty of $340 per return unless you show reasonable cause (as of October 2026). You can file up to 10 returns on paper without that penalty, and you can ask for a waiver on Form 8508.
How to prepare Forms 1095-C
- Count full-time and full-time equivalent employees for the previous year to confirm you're an ALE.
- Identify every employee who was full-time for at least one month.
- Record each month's offer of coverage and the employee's required contribution.
- Choose the right line 14 and line 16 codes.
- If your plan is self-insured, complete Part III for covered individuals.
- File with Form 1094-C, electronically if you're filing 10 or more returns.
- Furnish copies, or post the website notice and answer requests on time.
Most employers handle this through benefits administration software or their payroll provider, but the employer stays responsible for the codes.
If you're an employee who got a 1095-C
The IRS says employees may use the information to work out whether, for each month of the year, they can claim the premium tax credit on their own return. So if you bought individual health coverage, the line 14 and line 15 entries matter: they show whether you were offered employer coverage that month and what it would have cost you. Keep the form with your tax records.
My verdict
For a growing business, the real work in Form 1095-C is tracking hours and offers all year, not filling in the form in January. Use the new on-request option if it saves you a mailing, but only if your website notice is clear, and remember the 10-return e-file rule now catches almost every employer of this size.
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Frequently asked questions
What is Form 1095-C?
The form applicable large employers use to report the health coverage offered to each full-time employee for each month of the year.
Who has to file Form 1095-C?
Employers with 50 or more full-time employees, including full-time equivalents, in the previous year, known as applicable large employers.
Do employers still have to mail Form 1095-C to employees?
Not automatically. The 2025 instructions say employers can instead post a clear website notice that copies are available on request and furnish them on time.
When are 2025 Forms 1095-C due to the IRS?
March 2, 2026, on paper, or March 31, 2026, if filed electronically.
Must Form 1095-C be filed electronically?
Yes, if you're required to file 10 or more information returns during the year. You can ask for a waiver on Form 8508.
Can I get more time to file Forms 1095-C?
Yes. Form 8809 gives an automatic 30-day extension to file if you submit it by the due date, and no signature or explanation is needed.
Why does my Form 1095-C matter?
The IRS says employees may use it to decide whether they can claim the premium tax credit for each month of the year.
