Under the Affordable Care Act, insurers, employers and government programs report minimum essential coverage (MEC) to the IRS. Two of the forms they use are Form 1095-B and Form 1095-C.
Both are ACA reporting forms, but each serves a different purpose and comes from a different filer. Knowing which one applies to your organization helps you avoid costly compliance issues.
TL;DR - 1095-B vs. 1095-C
| Form 1095-B | Form 1095-C | |
|---|---|---|
| What it shows | That a person and their covered family members had MEC, and in which months | Whether a large employer offered coverage to a full-time employee, month by month, and what it cost |
| Who files it | Insurers, government programs (Medicaid, Medicare, CHIP) and small employers that sponsor self-insured plans | Applicable large employers (ALEs): 50 or more full-time employees, including full-time equivalents |
| Who receives it | The responsible individual for the coverage | Each full-time employee, plus anyone enrolled in the ALE’s self-insured plan |
| Transmittal form | Form 1094-B | Form 1094-C |
| Main use | Proof of coverage, including for state individual mandates | Enforcement of the employer mandate under section 4980H and premium tax credit eligibility |
| Hardest part | Accurate covered-person data, including SSNs or dates of birth | Tracking full-time status and coding lines 14 to 16 correctly every month |
What is Form 1095-B?
Form 1095-B is an IRS information return that reports the people who had minimum essential coverage during the year from a coverage provider that is not an applicable large employer.
For more on who issues it and the line 8 codes, see what Form 1095-B is.
It shows the coverage provider, the covered individuals, the type of coverage (Marketplace coverage is reported on Form 1095-A instead) and the months covered.
The form is usually issued by:
- Small employers that sponsor self-insured plans
- Health insurance companies, for insured coverage outside the Marketplace
- Government programs like Medicare, Medicaid and the Children’s Health Insurance Program (CHIP)
Purpose of Form 1095-B
The 1095-B form serves three purposes under the Affordable Care Act:
- It helps the IRS verify that the covered individual and their dependents had minimum essential coverage during the year.
- It gives covered individuals a record they can use if the IRS or a state asks about their coverage.
- It documents that the insurer, employer or government program met its own reporting duty.
Form 1095-B Issuance and Access for Employers
If you are a small employer sponsoring a self-insured plan, you file Form 1095-B with the IRS by February 28 on paper or March 31 electronically, moved to the next business day when the date falls on a weekend or legal holiday. For tax year 2025, that meant March 2, 2026 on paper or March 31, 2026 electronically. Copies to covered individuals were due March 2, 2026, which already includes the automatic 30-day extension from January 31.
If you cannot meet the IRS filing deadline, Form 8809 gives an automatic 30-day extension to file if you submit it by the due date.
Note: This extension does not apply to the deadline for furnishing copies to individuals.
You may also skip mailing Form 1095-B automatically. Instead, you can post a clear, conspicuous notice on your website that individuals may request a copy, keep it posted through October 15, and furnish any requested form by the later of January 31 or 30 days after the request. For tax year 2025, the notice had to be up by March 2, 2026.
Do Employers Need to Provide Form 1095-B for Tax Filing?
Covered individuals do not need Form 1095-B to file their federal returns, and the federal individual mandate penalty has been $0 since 2019.
The form can still matter for people in states that have their own individual mandate and need to show coverage on their state return.
Form 1095-B is a reporting obligation, not a tax filing document for your employees.
Types of Coverage Reported on Form 1095-B
Form 1095-B reports several categories of minimum essential coverage. The form keeps the same structure regardless of the coverage reported.
The single-letter code in Part I, line 8, identifies the origin of the coverage.
Some of the common coverage types reported include:
Employer-Sponsored Coverage (Self-Insured)
This includes self-insured medical plans sponsored by employers with fewer than 50 full-time employees, including full-time equivalents. Insurers also use this code for insured group coverage.
The filer reports this coverage using code B on line 8.
Government-Sponsored Programs
These are coverage options available through government programs, including Medicare, Medicaid and CHIP.
The government agency sponsoring the program files Form 1095-B for that coverage, using code C on line 8.
Individual Market Health Plan
This is minimum essential coverage bought directly from an insurance company, outside the Marketplace, and reported using code D on line 8.
What is Form 1095-C?
Form 1095-C is the IRS form an applicable large employer (50 or more full-time employees, including full-time equivalents) files for, and gives to, each full-time employee to report the health coverage it offered that employee each month and the employee’s cost for the lowest-cost self-only option.
For a line-by-line guide to the form and its codes, see what Form 1095-C is.
It shows employer and employee information, the offer of coverage (line 14), the employee required contribution (line 15) and any safe harbor or relief code (line 16). If the plan is self-insured, Part III also lists everyone who enrolled and the months they were covered.
ALEs file this form with the IRS, along with transmittal Form 1094-C, by February 28 on paper or March 31 electronically, and must furnish copies to full-time employees by March 2 (the January 31 deadline plus the automatic 30-day extension). For tax year 2025, those dates were March 2, 2026 (paper), March 31, 2026 (electronic) and March 2, 2026 (furnishing).
Purpose of Form 1095-C
The key purposes of Form 1095-C include:
- Helping the IRS confirm whether the ALE met the employer shared responsibility provision of the ACA or owes a payment under section 4980H. ALEs must offer their full-time employees minimum essential coverage that is affordable and provides minimum value.
- Determining an employee’s eligibility for the premium tax credit (PTC). A full-time employee may qualify for the PTC if the ALE did not offer coverage, or the coverage offered was not affordable or did not provide minimum value.
- Serving as a record for the ALE and the employee if either has to explain a coverage gap to the IRS.
Two changes from December 2024 also affect how the IRS uses these forms. The Employer Reporting Improvement Act gives an ALE at least 90 days to respond to the first letter proposing an employer shared responsibility payment (Letter 226-J), and it limits the IRS to six years from the Form 1094-C and 1095-C due date (or filing date, if later) to assess that payment, for returns due after December 31, 2024.
Are Employers Required to File Form 1095-C?
Yes, if you are an applicable large employer. An employer with 50 or more full-time employees, including full-time equivalents, in the prior calendar year must file a Form 1095-C for each employee who was full time in any month of the year, plus a Form 1094-C transmittal. This applies whether the plan is fully insured or self-insured, and even if the employer offered no coverage.
If your plan is self-insured, you also file Form 1095-C for anyone else enrolled, such as part-time employees, or report non-employees on Form 1095-B. If your plan is fully insured, you leave Part III blank and your insurer reports enrollment on Form 1095-B.
Your employees do not need Form 1095-C to file their federal tax returns, but they should keep it with their tax records.
How Employers Can Access and Manage Form 1095-C Online
Most employers deliver Form 1095-C through:
- Benefits portals
- Payroll systems
- Third-party vendor portals, if reporting is outsourced
Electronic delivery requires the employee’s consent. Since the Employer Reporting Improvement Act, an employee who gave affirmative consent to receive the statement electronically is treated as having consented going forward until they revoke it in writing.
Employees typically retrieve the form by logging in to the portal, opening tax documents and downloading their copy. If they consented to email delivery, HR can send it there.
ALEs may also use the alternative furnishing method under IRS Notice 2025-15: post a clear, conspicuous notice on your website by the furnishing deadline (March 2, 2026 for tax year 2025), keep it posted through October 15, and furnish a Form 1095-C within 30 days of any request.
Electronic Filing Requirements for Form 1095-C
If you file 10 or more information returns in a year, counting Forms W-2, 1099 and other information returns together, you must file Forms 1094-C and 1095-C electronically. You can file directly through the IRS ACA Information Returns (AIR) system or through a provider that transmits for you. Up to 9 returns can be filed on paper.
Here are the steps to follow:
Filing Directly Through the IRS AIR System
This is for employers that transmit their own returns:
- Compile the data the form requires, including employee and employer details and the codes for lines 14 to 16.
- Register for an IRS e-Services account and apply for an ACA Transmitter Control Code (TCC).
- Once you receive the TCC, generate your 1095-C returns in XML format with approved software.
- Complete the ACA Assurance Testing System (AATS) communication test with a test file.
- Once testing is complete and your TCC moves to production, transmit your final files through AIR.
- Keep a record of the Receipt ID issued when the transmission is accepted.
- Use the Receipt ID to check the acknowledgment status of your files.
- Fix any errors and submit corrections.
Filing Using an Authorized Provider
Here are the steps to file your Form 1095-C using this option:
- Set up an account on the provider’s platform.
- Upload your employee data in CSV or Excel format, or directly from your HR or payroll system.
- The software generates your forms in the required 1095-C format.
- Review the forms for accuracy and correct any errors.
- Approve the filing so the provider can transmit it.
For returns filed and statements furnished for tax year 2025, the penalty is $340 for each incorrect or late return and $340 for each incorrect or late statement, up to $4,098,500 a year for each, and $680 each with no cap for intentional disregard.
Relevant Characteristics Between Form 1095-B and 1095-C
Here is how Form 1095-B and Form 1095-C compare on the main characteristics:
| Form 1095-B | Form 1095-C | |
|---|---|---|
| Issued by | Insurers, government programs and small employers (fewer than 50 full-time employees, including equivalents) with self-insured plans | Applicable large employers (50 or more full-time employees, including equivalents) |
| Applies to | Individuals covered by minimum essential coverage during the calendar year | The ALE’s full-time employees, plus anyone enrolled in its self-insured plan |
| Primary focus | Coverage: the form shows you were covered | Offer: the form shows whether coverage was offered, at what cost, and, if self-insured, who enrolled |
| Furnishing deadline | January 31 plus automatic 30 days (March 2, 2026 for tax year 2025; March 2, 2027 for tax year 2026, per the IRS draft) | Same as Form 1095-B |
| IRS filing deadline | February 28 on paper or March 31 electronically, moved to the next business day on weekends (March 2 and March 31, 2026 for tax year 2025; March 1 and March 31, 2027 for tax year 2026, per the IRS draft) | Same as Form 1095-B |
| What the form contains | The responsible individual; each covered individual with SSN, or date of birth if no SSN; the coverage provider; months of coverage | The employee and the employer; offer codes (line 14); employee required contribution (line 15); safe harbor codes (line 16); covered individuals if self-insured (Part III) |
Similarities and Differences
Here are the key differences and similarities between the two forms.
Form 1095-B and 1095-C Differences
- Main Objective under IRS: Form 1095-B confirms that individuals and their dependents had minimum essential coverage. Form 1095-C confirms whether an ALE offered its full-time employees, and their dependents, qualifying coverage as the employer mandate requires.
- Premium Tax Credit Eligibility: Form 1095-B reports coverage only, not offers or cost. Form 1095-C line 15 reports the employee required contribution for the lowest-cost self-only coverage offered, which the IRS uses to check affordability and premium tax credit claims.
- Form Recipient: Form 1095-B goes to the responsible individual for coverage through an insurer, government program or small self-insured employer, regardless of employment status. Form 1095-C goes to an ALE’s full-time employees, and to anyone else enrolled in the ALE’s self-insured plan.
Form 1095-B and 1095-C Similarities
- ACA Reporting Requirements: Both are IRS information returns about health coverage during the tax year, and both are filed with a transmittal form (1094-B or 1094-C).
- Tax Filing: Neither form is needed to file a federal tax return. Individuals do not attach them or wait for them before filing.
- Filing and Distribution Timelines: Both share the same deadlines: February 28 on paper or March 31 electronically for the IRS, and the January 31 furnishing date plus the automatic 30-day extension for individuals. Both may use the furnish-upon-request notice method instead of automatic mailing.
- Missing taxpayer IDs: For returns due after December 31, 2024, the law allows a covered person’s full name and date of birth in place of a missing SSN or other TIN on either form.
The Bottom Line
Understanding the differences between Forms 1095-B and 1095-C matters whether you are an employer or a coverage provider.
It keeps your reports accurate and compliant with the Affordable Care Act. If you are an employer, your size, your full-time headcount and whether your plan is fully insured or self-funded decide which form you file and which parts you complete. Ethos supports employers with this reporting through its ACA compliance work.