# Form 1095-A vs. 1095-C. Which form you actually need.

Source: https://ethosbenefits.com/benefits-101/1095-a-vs-1095-c
Type: Benefits 101
Topic: ACA reporting
Author: Donovan Ryckis, Founder and CEO
Reviewed by: Patrick Ansara, Partner and Director of Client Operations
Publisher: Ethos Benefits
Published: 2026-02-13
Last updated: 2026-11-03
Cite as: "Form 1095-A vs. 1095-C," Ethos Benefits, https://ethosbenefits.com/benefits-101/1095-a-vs-1095-c, updated 2026-11-03.

**Short answer:** Form 1095-A comes from the Health Insurance Marketplace and reports Marketplace coverage and any advance premium tax credit, and the person who enrolled needs it to file Form 8962 with their tax return. Form 1095-C comes from an applicable large employer, reports the coverage offered to a full-time employee, and is not needed to file.

Employers that file Forms 1095-C often field the same question from employees every spring: "I got a 1095-A too. Which one do I need?" The two forms both report health coverage to the IRS, but they come from different places, serve different purposes, and only one of them is needed to file a tax return.

This page compares Form 1095-A with Form 1095-C. For the comparison between the two employer-side forms, see [Form 1095-B vs. 1095-C](https://ethosbenefits.com/benefits-101/1095-b-vs-1095-c).

## What is the difference between 1095-A and 1095-C?

Form 1095-A reports Marketplace coverage and the premium tax credit, and the person who enrolled needs it to file. Form 1095-C reports what a large employer offered, and the employee does not need it to file.

| | **Form 1095-A** | **Form 1095-C** |
| --- | --- | --- |
| **Full name** | Health Insurance Marketplace Statement | Employer-Provided Health Insurance Offer and Coverage |
| **Who sends it** | The Health Insurance Marketplace (HealthCare.gov or a state exchange) | An applicable large employer (ALE): 50 or more full-time employees, including full-time equivalents |
| **Who receives it** | The person who enrolled in a Marketplace plan | Each employee who was full time for any month, plus anyone enrolled in the ALE's self-insured plan |
| **What it reports** | Covered people, monthly premiums, the benchmark silver plan premium and advance premium tax credit payments | The offer of coverage (line 14), the employee's cost for the lowest-cost self-only option (line 15) and safe harbor or relief codes (line 16) |
| **Needed to file a tax return?** | Yes, if advance credit was paid or a credit is claimed: it feeds Form 8962 | No. Keep it with tax records |
| **Deadline to individuals** | January 31 (for 2025 coverage, January 31, 2026) | January 31 plus an automatic 30 days (for tax year 2025, March 2, 2026) |
| **Main IRS use** | Reconciling the premium tax credit | Enforcing the employer mandate under section 4980H and checking premium tax credit eligibility |

## What is Form 1095-A?

Form 1095-A is the statement the Health Insurance Marketplace sends to each person who enrolled in a qualified health plan through it. The Marketplace also sends a copy to the IRS.

The form has three parts:

- **Part I** identifies the Marketplace, the policy, the insurer and the recipient.
- **Part II** lists everyone covered under the policy and their coverage dates.
- **Part III** shows, for each month, the enrollment premium (column A), the premium for the second lowest cost silver plan used as the benchmark (column B) and the advance premium tax credit paid to the insurer (column C).

The Marketplace must furnish Form 1095-A by January 31 of the following year, moved to the next business day when that date falls on a weekend or holiday. For 2025 coverage, that was January 31, 2026. People who have not received it by early February should contact the Marketplace, and most can download it from their Marketplace account. If a corrected form arrives, use the corrected one, and never use a form marked "VOID."

## Why is the 1095-A needed to file?

Form 1095-A is the only one of the three 1095 forms a person needs to complete their return. The premium tax credit is estimated in advance and paid to the insurer each month, then settled on the tax return using Form 8962, and Form 8962 is built from the numbers in Part III of the Form 1095-A.

Form 8962 compares the advance credit paid during the year with the credit the person actually qualifies for based on final household income:

- If the advance payments were too low, the difference increases the refund or lowers the tax owed.
- If the advance payments were too high, the excess is repaid with the return.

Anyone who had advance payments of any amount must file Form 8962 with their return. Filing without it can delay a refund and can make the person ineligible for advance payments in a later year.

Forms 1095-B and 1095-C work differently. They are information returns, and no one needs them to complete a federal return.

### What changed for 2026 coverage.

The enhanced premium tax credits that Congress created for 2021 through 2025 expired at the end of 2025. Current IRS guidance (reviewed September 2026) again limits the credit to households with income from 100 to 400 percent of the federal poverty line, and Congress has not enacted an extension as of this update. For 2026, expected contributions under Rev. Proc. 2025-25 range from 2.10 percent of income at the lowest incomes to 9.96 percent at 300 to 400 percent of the poverty line.

The cap on repaying excess advance credit also ended. For tax years after 2025, a person whose advance credit was too high repays the full excess on Form 8962. For employees with Marketplace coverage in 2026, getting the 1095-A right, and reporting income changes to the Marketplace during the year, matters more than it did.

## What is Form 1095-C?

Form 1095-C is the statement an applicable large employer files with the IRS and gives to each full-time employee, showing month by month whether the employer offered health coverage and what it cost. If the plan is self-insured, Part III also lists everyone enrolled and the months they were covered.

The lines that matter most for the Marketplace are in Part II:

- **Line 14** shows the offer. For example, code 1A is a qualifying offer, 1E is minimum value coverage offered to the employee with coverage offered to a spouse and dependents, and 1H means no offer.
- **Line 15** shows the employee required contribution: the monthly cost of the lowest-cost self-only coverage that provides minimum value.
- **Line 16** explains the month. For example, 2C means the employee enrolled, 2A means the employee was not employed that month, and the affordability safe harbor codes (2F, 2G and 2H) show which test the employer used.

ALEs file Forms 1094-C and 1095-C with the IRS by February 28 on paper or March 31 electronically, and furnish copies to employees by the January 31 deadline plus an automatic 30-day extension. Employers can also use the furnish-upon-request method under IRS Notice 2025-15 in place of mailing every form. The [Form 1095-C](https://ethosbenefits.com/benefits-101/form-1095-c) explainer covers the codes, deadlines and filing steps in detail.

## Why would an employee get both forms?

An employee receives both forms in the same year when they had Marketplace coverage for some months and worked full time for a large employer for some months. The common cases are:

1. **Marketplace coverage before or after the job.** The employee had a Marketplace plan for part of the year, then started with a large employer (or left one). The 1095-A covers the Marketplace months, and the 1095-C covers the months of employment.
2. **A waiting period.** A new full-time hire keeps a Marketplace plan until employer coverage starts. The 1095-C typically shows code 1H with a line 16 code for the limited non-assessment period during those months.
3. **The employee declined the employer's offer.** A full-time employee turned down the employer plan and bought a Marketplace plan instead. Both forms cover the same months, and the 1095-C shows what the employee was offered and at what cost.
4. **Family members on the Marketplace.** The employee enrolled in the employer plan, but a spouse or children bought Marketplace coverage. Since 2023, family members can qualify for the credit when the employee's cost for family coverage is unaffordable, even if self-only coverage is affordable.

In each case, the employee uses the 1095-A to file and keeps the 1095-C as a record.

## How does the 1095-C affect the premium tax credit?

Form 1095-C is how the IRS checks whether a full-time employee was entitled to the premium tax credit claimed with a Form 1095-A. An employee generally cannot take the credit for any month they were offered employer coverage that was affordable and provided minimum value, whether or not they enrolled. An employee who enrolls in employer coverage cannot take the credit for those months even if the coverage was unaffordable.

Affordability is measured against household income. For plan years beginning in 2026, employer coverage is affordable if the employee's cost for self-only coverage is no more than 9.96 percent of household income (9.02 percent for 2025). Employers do not know household income, so most rely on an [affordability safe harbor](https://ethosbenefits.com/benefits-101/aca-affordability-safe-harbor) based on W-2 wages, rate of pay or the federal poverty line, and report it on line 16.

| What the 1095-C shows for a month | What it means for the employee's credit |
| --- | --- |
| Code 1A (qualifying offer) | Generally not eligible for the credit that month |
| Affordable, minimum value offer on line 14 and 15, declined | Generally not eligible, whatever the employee chose |
| Code 2C (enrolled in employer coverage) | Not eligible for that month |
| Code 1H (no offer) | May be eligible if income and other rules are met |
| Offer that was unaffordable or not minimum value | May be eligible |

The employee's credit and the employer's penalty exposure are linked. A credit the employee should not have received can become a problem for both.

## How does the 1095-C affect the employer's 4980H exposure?

Under section 4980H, an applicable large employer owes an employer shared responsibility payment only if at least one full-time employee receives a premium tax credit for Marketplace coverage. That is why the Marketplace data behind the 1095-A and the employer's 1095-C data meet at the IRS.

There are two kinds of payment, both indexed each year. For 2026, under Rev. Proc. 2025-26:

| Payment | When it applies | 2026 annual amount |
| --- | --- | --- |
| **4980H(a)** | The employer did not offer coverage to at least 95 percent of full-time employees and their dependents, and at least one full-time employee received a premium tax credit | $3,340 per full-time employee, minus the first 30 |
| **4980H(b)** | The employer offered coverage, but at least one full-time employee received a premium tax credit because they were not offered coverage or the offer was unaffordable or not minimum value | $5,010 per full-time employee who received a credit, capped at the 4980H(a) amount |

When the IRS matches a credit to a full-time employee and the 1095-C does not show an offer or a safe harbor that rules out the payment, it sends Letter 226-J. The letter proposes a payment and includes Form 14765, the Employee Premium Tax Credit listing, showing each employee and month involved. The IRS bases the proposal on the employer's Forms 1094-C and 1095-C together with employees' individual returns.

Two rules from the Employer Reporting Improvement Act of December 2024 now apply:

- **At least 90 days to respond.** The IRS must give an ALE at least 90 days from the date of the first letter proposing a 4980H payment before taking further action.
- **A six-year limit.** For returns due after December 31, 2024, the IRS has six years from the Form 1094-C and 1095-C due date (or filing date, if later) to assess a 4980H payment.

Many Letter 226-J proposals come from coding errors rather than real failures: a 1H where an offer was made, a missing line 16 safe harbor code, or a part-time employee reported as full time. Accurate line 14 to 16 coding is the employer's best protection, because it is the evidence the IRS reads first.

## What employers should do.

1. **Code lines 14 to 16 for every month,** including waiting periods, new hires and terminations, and make sure the safe harbor on line 16 matches the one your contribution was actually set against.
2. **Check affordability before the plan year** using the new percentage (9.96 percent for 2026), so an offer does not become unaffordable without anyone noticing.
3. **Tell employees which form they need.** A short note with the 1095-C explaining that it is not needed to file, and that a Form 1095-A from the Marketplace is, saves HR a lot of questions.
4. **Keep offer records,** such as enrollment elections and waivers, for at least six years so you can answer a Letter 226-J within the 90-day window.

Ethos Benefits helps employers with this reporting and with Letter 226-J responses through its [ACA compliance work](https://ethosbenefits.com/services/aca-compliance).

## Frequently asked questions

### What is the difference between Form 1095-A and Form 1095-C?

Form 1095-A comes from the Health Insurance Marketplace and reports Marketplace coverage, premiums and any advance premium tax credit. Form 1095-C comes from an applicable large employer and reports the coverage it offered a full-time employee and the employee's cost. The person who enrolled uses the 1095-A to complete Form 8962, while the 1095-C is kept with tax records and is not needed to file.

### Do I need a 1095-C to file my taxes if I also have a 1095-A?

No. You use the Form 1095-A to complete Form 8962 and file your return, and you keep the Form 1095-C with your records. Employees never attach a 1095-C or enter it on a federal return. If the 1095-A has not arrived by early February, download it from your Marketplace account or contact the Marketplace before you file.

### What should you do if you received both a 1095-A and a 1095-C?

Use the 1095-A to file and keep the 1095-C. Before filing, compare the months on each form. For any month the 1095-C shows an affordable, minimum value offer from the employer, or shows you enrolled in the employer plan, you generally cannot take the premium tax credit, and claiming it can lead to repaying the credit later.

### How does Form 1095-A affect my tax refund?

Form 1095-A can raise or lower your refund. Its numbers feed Form 8962, which compares the advance premium tax credit paid during the year with the credit you qualify for based on final household income. If the advance payments were too low, your refund grows. If they were too high, you repay the excess, and for tax years after 2025 there is no repayment cap.

### Is Form 1095-A needed if you have employer coverage?

Only for months you were enrolled in a Marketplace plan. If you had employer coverage all year and no Marketplace plan, you will not receive a Form 1095-A and do not need one. Your employer sends a Form 1095-C if it is an applicable large employer, and that form is for your records, not for completing the return.

### Do employers file Form 1095-A?

No. Only the Health Insurance Marketplace files Form 1095-A. An applicable large employer files Forms 1094-C and 1095-C with the IRS instead, and furnishes a 1095-C to each full-time employee. The IRS compares that employer data with the premium tax credits employees claim on Form 8962, which is how a Letter 226-J proposing a 4980H payment can start.

### What is the difference between Form 1095-A, 1095-B and 1095-C?

The difference is who sends each form. The Marketplace sends Form 1095-A for Marketplace coverage, and it is the only one needed to file. Insurers, government programs such as Medicaid, and self-insured employers that are not applicable large employers send Form 1095-B to show coverage. Applicable large employers send Form 1095-C to show the coverage they offered.

## Sources

1. [Instructions for Form 8962 (2025)](https://www.irs.gov/instructions/i8962), Internal Revenue Service
2. [Instructions for Form 1095-A (2025)](https://www.irs.gov/instructions/i1095a), Internal Revenue Service
3. [Instructions for Forms 1094-C and 1095-C (2025)](https://www.irs.gov/instructions/i109495c), Internal Revenue Service
4. [Questions and answers on the Premium Tax Credit](https://www.irs.gov/affordable-care-act/individuals-and-families/questions-and-answers-on-the-premium-tax-credit), Internal Revenue Service
5. [Rev. Proc. 2025-25 (2026 applicable percentage table and required contribution percentage)](https://www.irs.gov/pub/irs-drop/rp-25-25.pdf), Internal Revenue Service
6. [Rev. Proc. 2025-26 (2026 section 4980H payment amounts)](https://www.irs.gov/pub/irs-drop/rp-25-26.pdf), Internal Revenue Service
7. [Understanding your Letter 226-J](https://www.irs.gov/individuals/understanding-your-letter-226-j), Internal Revenue Service
8. [26 U.S. Code § 4980H, Shared responsibility for employers regarding health coverage](https://www.law.cornell.edu/uscode/text/26/4980H), Legal Information Institute, Cornell Law School
9. [26 U.S. Code § 6501, Limitations on assessment and collection](https://www.law.cornell.edu/uscode/text/26/6501), Legal Information Institute, Cornell Law School
10. [Instructions for Forms 1094-B and 1095-B (2025)](https://www.irs.gov/instructions/i109495b), Internal Revenue Service
11. [Questions and answers about health care information forms for individuals](https://www.irs.gov/affordable-care-act/questions-and-answers-about-health-care-information-forms-for-individuals), Internal Revenue Service