# What is Form 1095-C? The employer coverage form, line by line.

Source: https://ethosbenefits.com/benefits-101/form-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: 2026-02-17
Last updated: 2026-11-03
Cite as: "What is Form 1095-C?," Ethos Benefits, https://ethosbenefits.com/benefits-101/form-1095-c, updated 2026-11-03.

**Short answer:** Form 1095-C is the IRS form an applicable large employer, one with 50 or more full-time employees including equivalents, gives each full-time employee to report the health coverage it offered that employee each month and the cost of the cheapest employee-only option. Employees do not need it to file their taxes, but should keep it.

## What is Form 1095-C used for?

Form 1095-C, Employer-Provided Health Insurance Offer and Coverage, is the information return an applicable large employer (ALE) files with the IRS, and gives to each full-time employee, under section 6056 of the Internal Revenue Code. It shows, month by month, whether the employer offered that employee health coverage, what the employee would have paid for the cheapest employee-only option, and which safe harbor or relief applied. If the plan is self-insured, it also lists everyone who was covered.

The IRS uses it for two things:

1. **The employer mandate.** It checks whether the employer offered affordable, minimum value coverage to its full-time employees, or owes an employer shared responsibility payment under section 4980H.
2. **The premium tax credit.** An employee who bought Marketplace coverage generally can't get the credit for months the employer made an affordable, minimum value offer. Form 1095-C is how the IRS checks.

If you are trying to work out whether you should have a 1095-B or a 1095-C, see [Form 1095-B vs. 1095-C](https://ethosbenefits.com/benefits-101/1095-b-vs-1095-c). This page covers the 1095-C itself.

## Who gets a Form 1095-C?

An employer that had 50 or more full-time employees, including full-time equivalents, in the prior calendar year is an ALE. It must file a Form 1095-C for every employee who was full time for at least one month of the year, plus a Form 1094-C transmittal. That holds whether the plan is fully insured or self-insured, and even if the employer offered no coverage at all.

| Situation | Does the employee get a 1095-C? |
| --- | --- |
| Full time for at least one month at an ALE | Yes |
| Part time all year, not enrolled in coverage | No |
| Part time all year, enrolled in the ALE's self-insured plan | Yes, with code 1G on line 14 |
| Nonemployee (retiree, director, prior-year COBRA) in the self-insured plan | The employer may use Form 1095-C or Form 1095-B |
| Employee of a company with fewer than 50 full-time employees | No. A small self-insured employer files Form 1095-B instead |

Each company in a controlled group files separately. An employee who worked full time for two related companies during the year can receive two Forms 1095-C.

## Part I, employee and employer.

Part I identifies who the form is about and who sent it.

| Lines | What they show |
| --- | --- |
| 1 to 6 | The employee's name, Social Security number and address |
| 7 to 13 | The employer's name, EIN, address and a contact phone number |

Part I has no date of birth line. The form does ask for the employee's age on January 1, but only when the employer offered an individual coverage HRA (ICHRA). Part II also starts with a required **plan start month** box: the two-digit month the plan year begins, or "00" if no plan was offered.

## Part II, the offer of coverage.

Part II is where most questions and most errors come from. It has a box for each month, and an "All 12 Months" box the employer can use when a code or amount is the same all year.

### Line 14: offer of coverage codes.

Line 14 says what the employer offered that month. These are the codes you will see most often:

| Code | What it means |
| --- | --- |
| **1A** | Qualifying Offer: minimum essential coverage providing minimum value offered to the full-time employee, at a cost to the employee of no more than 9.5% (as adjusted) of the mainland single federal poverty line, with at least minimum essential coverage offered to the spouse and dependents |
| **1B** | Minimum essential coverage providing minimum value offered to the employee only |
| **1C** | Minimum value coverage offered to the employee, and at least minimum essential coverage offered to dependents (not the spouse) |
| **1E** | Minimum value coverage offered to the employee, and at least minimum essential coverage offered to dependents and the spouse |
| **1H** | No offer of coverage, or an offer of coverage that is not minimum essential coverage |

Other codes cover narrower cases. 1D is employee plus spouse only. 1F is coverage that does not provide minimum value. 1G is for someone who was never a full-time employee but enrolled in the self-insured plan. 1J and 1K cover conditional spousal offers, and 1L through 1U cover ICHRA offers. A former employee on COBRA after termination is reported with 1H on line 14 and 2A on line 16, not as an offer.

### Line 15: the employee's cost.

Line 15 shows the **employee required contribution**: the employee's monthly share of the cost for the lowest-cost, self-only coverage providing minimum value that was offered. It is not necessarily what the employee actually paid. An employee who chose family coverage or a richer plan still shows the cheapest self-only price here.

- Enter the amount to the cent. If the offer cost the employee nothing, enter 0.00 rather than leaving it blank.
- Leave line 15 blank when line 14 is 1A, 1F, 1G or 1H.
- The IRS compares this amount with the employee's household income to judge affordability. The affordability percentage is 9.02% for plan years beginning in 2025 and 9.96% for plan years beginning in 2026.

Employers usually can't see household income, so most test affordability with a safe harbor. See [the ACA affordability safe harbors](https://ethosbenefits.com/benefits-101/aca-affordability-safe-harbor) for how each one works.

### Line 16: safe harbor and relief codes.

Line 16 explains why the employer should not owe a 4980H(b) payment for that employee in that month, even if line 14 alone would raise a question. Only one code goes in each month, and the line is left blank if none applies.

| Code | What it means |
| --- | --- |
| **2A** | Employee not employed on any day of the month |
| **2B** | Employee not full time that month and not enrolled. Also used for a full-time employee whose coverage ended before month end only because employment ended |
| **2C** | Employee enrolled in the coverage offered for every day of the month. This generally takes priority over every other code |
| **2D** | Employee in a section 4980H(b) limited non-assessment period, such as a waiting period or an initial measurement period |
| **2F** | Affordability safe harbor based on Form W-2 wages. If used, it applies for every month the employee was offered coverage |
| **2G** | Affordability safe harbor based on the federal poverty line |
| **2H** | Affordability safe harbor based on the employee's rate of pay |

Two rules trip up a lot of filers. There is no code for an employee who waived coverage, so for a full-time employee who declined an affordable offer, the employer uses an affordability safe harbor code if one applies. And an affordability safe harbor code can't be used in any month the employer did not offer coverage to at least 95% of its full-time employees and their dependents.

### Line 17: ICHRA ZIP code.

Line 17 is used only for ICHRA offers. It shows the ZIP code used to find the lowest-cost silver plan for the affordability test: the employee's home ZIP, or the work site ZIP if the employer uses the location safe harbor.

## Part III, self-insured plans only.

Part III lists every person covered under the employee's enrollment, with each person's name, SSN (or date of birth if there is no SSN) and the months they were covered. Only an employer with a self-insured plan, including an ICHRA, completes it.

If the plan is fully insured, Part III stays blank and the insurance carrier reports who was covered on Form 1095-B. An employer with both kinds of plans completes Part III only for employees enrolled in the self-insured option.

## What do employees do with Form 1095-C?

Keep it. Form 1095-C is a record, not a filing document.

- **You don't need it to file.** You do not attach it to your return, and you don't need to wait for it before filing.
- **It matters if you bought Marketplace coverage.** If you received advance premium tax credits, line 14 and line 15 show whether your employer made an affordable, minimum value offer that would make you ineligible.
- **Check that it's right.** Confirm your name, SSN and the months shown. If something is wrong, contact the employer listed in Part I, not the IRS.
- **You may not get one automatically.** Since tax year 2024, employers may post a notice that forms are available on request instead of mailing them. If your employer does that, ask for a copy and it must send one within 30 days.

## What do employers have to do?

Filing and furnishing Form 1095-C is the employer's legal duty, even when a payroll vendor or reporting service prepares it. The deadlines move to the next business day when they fall on a weekend or holiday.

| Step | Tax year 2025 | Tax year 2026 (IRS draft) |
| --- | --- | --- |
| Furnish to employees (January 31 plus an automatic 30 days) | March 2, 2026 | March 2, 2027 |
| File with the IRS on paper | March 2, 2026 | March 1, 2027 |
| File with the IRS electronically | March 31, 2026 | March 31, 2027 |

**Electronic filing.** An employer filing 10 or more information returns in a year, counting Forms W-2, 1099 and others together, must file Forms 1094-C and 1095-C electronically through the IRS ACA Information Returns (AIR) system, directly or through a provider that transmits for it. Form 8809 gives an automatic 30-day extension to file with the IRS if submitted by the due date. There is no further extension for furnishing to employees.

**The alternative furnishing method.** The Paperwork Burden Reduction Act, signed in December 2024, lets an employer skip automatic mailing. Under IRS Notice 2025-15, the employer posts a clear, conspicuous notice on its website that employees may request their form, with an email address, mailing address and phone number. The notice must go up by the furnishing deadline (March 2, 2027 for tax year 2026) and stay up through October 15. Any requested form must be furnished within 30 days of the request, or by January 31 (moved to the next business day) if that is later.

**Other changes from December 2024.** The Employer Reporting Improvement Act lets an employer report a covered person's date of birth when an SSN is missing. It treats an employee who once consented to electronic delivery as having consented going forward. It also gives employers at least 90 days to respond to a Letter 226-J proposing a 4980H payment, and limits the IRS to six years from the Form 1094-C and 1095-C due date (or filing date, if later) to assess one.

**Penalties.** For returns and statements for tax year 2025, the penalty is $340 for each late or incorrect return and $340 for each late or incorrect employee statement, up to $4,098,500 a year for each. The 2026 draft keeps $340 and raises the cap to $4,191,500. Intentional disregard carries higher penalties with no cap.

## What mistakes should employers check for?

- **Wrong amount on line 15.** Entering what the employee actually paid for family or buy-up coverage instead of the lowest-cost self-only price.
- **Missing line 16 codes.** Leaving line 16 blank for a full-time employee who waived an affordable offer, when an affordability safe harbor code applied.
- **Part III errors.** Leaving out dependents on a self-insured plan, or completing Part III for a fully insured plan.
- **Bad SSNs.** Mismatched names and SSNs are a common reason for IRS error notices. Pull data from payroll and check it before filing.
- **Assuming the vendor has it.** A vendor can prepare and transmit the forms, but the employer stays responsible for what they say.

For more on the whole filing cycle, see [ACA reporting](https://ethosbenefits.com/benefits-101/aca-reporting). Ethos Benefits reviews 1095-C coding and filing for employers as part of its [ACA compliance work](https://ethosbenefits.com/services/aca-compliance).

## Frequently asked questions

### Is a 1095-C required for 2025 taxes?

No. Employees do not need Form 1095-C to file a 2025 federal return, and they should not wait for it before filing. Nothing from the form is entered on the return or attached to it. Keep it with your tax records, because it shows what your employer offered if you or a family member had Marketplace coverage with a premium tax credit.

### Does a 1095-C affect my taxes?

Not directly. Form 1095-C does not change your refund or the tax you owe. It matters only if you claimed a premium tax credit for Marketplace coverage, because the IRS uses it to check whether your employer offered affordable, minimum value coverage. For any month you had such an offer or enrolled in the employer plan, you generally cannot take the credit.

### How do I get my 1095-C form online?

Ask your employer, because only the employer issues Form 1095-C. Many employers post it in their payroll or HR portal if you consented to electronic delivery. Since tax year 2024, an employer may also post a website notice that forms are available on request instead of mailing them, and must send a requested form within 30 days.

### What is the difference between Form 1095-C and Form W-2?

Form W-2 reports your wages and tax withholding, and you use it to file your return. Form 1095-C reports the health coverage your employer offered you each month and what the lowest-cost self-only option cost, which the IRS uses to check the employer mandate and premium tax credit claims. You need the W-2 to file, but not the 1095-C.

### Can I receive more than one Form 1095-C in a year?

Yes. If you were a full-time employee of more than one applicable large employer during the year, including separate companies in the same corporate group, each one files its own Form 1095-C for you. Each form covers only the months you worked for that employer, and you keep all of them with your tax records.

### Do part-time employees get a Form 1095-C?

Only in some cases. A large employer must file a Form 1095-C for any employee who enrolled in its self-insured plan, full time or not, and uses code 1G on line 14 for an employee who was never full time during the year. An employee who was full time for even one month of the year also gets one.

### When are 1095-C forms due to employees?

For tax year 2025, employees had to receive it by March 2, 2026, and returns were due to the IRS by March 2, 2026 on paper or March 31, 2026 electronically. For tax year 2026, the IRS draft instructions set March 2, 2027 for employees and March 1, 2027 (paper) or March 31, 2027 (electronic) for the IRS.

## Sources

1. [Instructions for Forms 1094-C and 1095-C (2025)](https://www.irs.gov/instructions/i109495c), Internal Revenue Service
2. [2026 Instructions for Forms 1094-C and 1095-C (early release draft)](https://www.irs.gov/pub/irs-dft/i109495c--dft.pdf), Internal Revenue Service
3. [Form 1095-C, Employer-Provided Health Insurance Offer and Coverage](https://www.irs.gov/pub/irs-pdf/f1095c.pdf), Internal Revenue Service
4. [Questions and Answers about Information Reporting by Employers on Form 1094-C and Form 1095-C](https://www.irs.gov/affordable-care-act/employers/questions-and-answers-about-information-reporting-by-employers-on-form-1094-c-and-form-1095-c), Internal Revenue Service
5. [Notice 2025-15, Alternative Manner of Furnishing Certain Health Insurance Coverage Statements (Internal Revenue Bulletin 2025-11)](https://www.irs.gov/irb/2025-11_IRB), Internal Revenue Service
6. [Rev. Proc. 2025-25, 2026 Required Contribution Percentage](https://www.irs.gov/pub/irs-drop/rp-25-25.pdf), Internal Revenue Service
7. [26 U.S. Code § 6056, Certain employers required to report on health insurance coverage](https://www.law.cornell.edu/uscode/text/26/6056), Legal Information Institute, Cornell Law School
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