1094-C Transmittal Form Requirements

Form 1094-C serves as the transmittal cover sheet that Applicable Large Employers (ALEs) file with the IRS alongside individual Form 1095-C statements. Filed under the Affordable Care Act's employer reporting framework at 26 U.S.C. § 6056, the 1094-C carries aggregate employer-level data that the IRS uses to assess whether an ALE met its obligations under the employer mandate. Understanding its distinct requirements — separate from the line-level 1095-C — is essential for any organization subject to ACA reporting. The regulatory context for ACA employer reporting traces this requirement to the Internal Revenue Code provisions added by the ACA in 2010.

Definition and scope

Form 1094-C is the IRS transmittal document that accompanies a batch of Form 1095-C returns when filed by an Applicable Large Employer. The IRS defines it as "Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns" (IRS Instructions for Forms 1094-C and 1095-C).

An ALE is any employer that employed an average of at least 50 full-time employees, including full-time equivalent employees, during the prior calendar year (26 U.S.C. § 4980H(c)(2)). Each ALE member files its own 1094-C with the IRS; a controlled group in which five separate entities each qualify as ALE members must therefore file 5 separate 1094-C transmittals.

The 1094-C collects three distinct categories of information:

1. Employer identification — Legal name, EIN, address, and contact information.
2. Aggregate employer data — Total number of 1095-C forms filed with that submission, and total employee count by month.
3. Offer of coverage indicators — The Authoritative Transmittal designation, minimum essential coverage indicators, and eligibility for transition relief.

Only one 1094-C per ALE member is designated as the Authoritative Transmittal. This specific document carries the monthly employee count, the certification of eligibility for qualifying offers or transition relief, and the indicator as to whether the ALE member offered minimum essential coverage to at least 95% of its full-time employees. Non-authoritative transmittals may accompany partial batches of 1095-C forms but must not carry the Authoritative Transmittal checkbox.

How it works

The filing process for Form 1094-C follows a structured sequence governed by IRS Publication instructions updated each filing season.

1. Prepare all Form 1095-C statements for every full-time employee employed during the reporting year. The total count of 1095-C forms filed is entered in Part I, Line 18 of the 1094-C.
2. Designate the Authoritative Transmittal. Check Box "A" on Line 19 of Part I on exactly one 1094-C submission. The IRS uses this document to reconcile employer-level data against potential employer mandate penalties (§4980H).
3. Complete Part II — ALE Member Information. This section captures the total number of Forms 1095-C filed for the ALE member across all submissions (Line 20), and identifies whether the ALE is a member of an Aggregated ALE Group (Line 21).
4. Complete Part III on the Authoritative Transmittal only. Part III records month-by-month minimum essential coverage offers and full-time employee headcounts across all 12 calendar months, plus the annual totals. Columns (a), (b), and (c) track: whether MEC was offered to ≥95% of full-time employees, the total employee count, and the full-time employee count, respectively.
5. Complete Part IV if applicable. Part IV lists up to 30 other ALE members in the Aggregated ALE Group. If the group exceeds 30 members, a second 1094-C continuation sheet is used.
6. Submit electronically if filing 10 or more information returns in aggregate across all return types for the tax year (26 U.S.C. § 6011(e); the 10-return threshold was lowered from 250 by the Taxpayer First Act and implementing regulations effective for returns filed after December 31, 2023 — see TD 9972, IRS.gov). Electronic filing is done through the IRS ACA Information Returns (AIR) system.

Paper filings, permitted only when the 10-return threshold is not met, must be mailed to the address specified in the current year's IRS Instructions for Forms 1094-C and 1095-C.

Common scenarios

Scenario 1 — Single ALE member, all 1095-Cs in one batch
A single employer with 200 full-time employees files one 1094-C marked as the Authoritative Transmittal with all 200 Form 1095-Cs. Part III is fully completed. This is the simplest configuration.

Scenario 2 — Multiple batches, one ALE member
An ALE member submits 1,500 Form 1095-Cs in 3 electronic batches of 500. One 1094-C in exactly one batch carries the Authoritative Transmittal designation. The other two 1094-Cs are non-authoritative and leave Part III blank. Part I, Line 18 of each non-authoritative 1094-C reflects only the 500 forms in that batch, while Line 20 of the Authoritative Transmittal reflects the full 1,500.

Scenario 3 — Controlled group with 4 ALE members
Four entities under common ownership each qualify independently as ALE members. Each files its own Authoritative Transmittal. Each lists the other 3 entities in Part IV. The IRS treats these as related but processes each 1094-C as a separate employer-level filing. See controlled group and affiliated service group rules for how common ownership affects ALE determination.

Scenario 4 — Transition relief certification
An ALE member that qualifies for the 4980H(b) penalty safe harbor under Section 4980H transition relief checks the applicable box in Part II, Line 22 (Box B or Box D, as applicable for the relevant year). This designation is available only on the Authoritative Transmittal.

Decision boundaries

The table below summarizes key distinctions between the Authoritative Transmittal and non-authoritative transmittals:

Electronic vs. paper filing threshold: ALEs filing 10 or more information returns in aggregate must file electronically through the AIR system. A failure to file electronically when required triggers penalties under 26 U.S.C. § 6721, which sets a base penalty of $310 per return for failures in 2024, with an annual cap of $3,783,000 for large filers (IRS Revenue Procedure 2023-34).

ALE group member vs. single employer: A standalone employer that is not part of any controlled or affiliated service group completes Part IV with no entries. An ALE member within a group must list related entities in Part IV even if those entities file their own separate 1094-Cs. Omission of Part IV data does not eliminate penalty exposure; the IRS reconciles Aggregated ALE Group membership independently.

Amended vs. corrected returns: If an error is discovered after submission, a corrected 1094-C is filed by checking the "CORRECTED" box on Line 14. An amended Authoritative Transmittal replaces the prior Authoritative Transmittal in its entirety. The process for corrections is addressed in detail at correcting ACA reporting errors, and common 1095-C errors covers related line-level issues that often prompt transmittal corrections.

The ACA site index provides orientation to the full range of employer reporting obligations, including 1095-C reporting requirements overview and filing deadlines and extensions, which govern the calendar dates by which the 1094-C must reach the IRS.

References

• IRS — About Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
• IRS Instructions for Forms 1094-C and 1095-C (current year)
• [26 U.S.C. § 6056 — Statements relating to health insurance coverage (Cornell LII)](https://www.law.cornell.edu/uscode/text/26/6

The law belongs to the people. Georgia v. Public.Resource.Org, 590 U.S. (2020)