Are 1095-C Forms Still Required? 2026 Deadlines and Penalties

Yes — Form 1095-C is still required. Every applicable large employer must file 1095-Cs with the IRS for the 2025 tax year and make them available to employees. What changed is how you get the form into employees’ hands: since the 2023 tax year, employers no longer have to automatically mail a copy to each person. You can instead post a notice on your company website and furnish the form on request. The IRS filing side is unchanged, and the penalties for skipping it have gone up for 2026.

Who Still Has to File

The obligation attaches to applicable large employers, or ALEs. You’re an ALE if you employed an average of at least 50 full-time employees, including full-time equivalents, during the prior calendar year. A full-time employee is anyone averaging at least 30 hours per week or 130 hours per month.¹

Full-time equivalents catch employers who lean on part-time staff. Add up the monthly hours of your part-time workers, divide by 120, and add that to your headcount of actual full-time employees. If the twelve-month average lands at 50 or more, you’re in.

What you report depends on how you fund coverage. Self-insured employers, who pay claims directly, report both the offer of coverage and detailed enrollment data for every covered individual including dependents. Employers with a fully insured plan report the coverage offer and the employee’s share of the lowest-cost option, and the insurance carrier handles enrollment reporting separately on Form 1095-B.¹

Small employers below the 50-employee threshold are not required to file 1095-C at all. If that’s you, this article isn’t your obligation.

What Actually Changed: The Alternative Furnishing Method

This is the rule change that has employers asking whether 1095-C is still required. Starting with the 2023 tax year (forms due in early 2024), employers no longer have to automatically mail Form 1095-C to every employee. You can satisfy the furnishing requirement by posting a clear notice on your company website and then providing a copy within 30 days when an employee asks for one.²

The notice has specifications. It must be written in plain language, with text large enough to catch a viewer’s attention. It has to say that employees can receive a copy of their form on request, and it must list an email address, a physical mailing address, and a phone number. The IRS example that passes muster: a “Tax Information” link on the main page leading to a secondary page headed “IMPORTANT HEALTH COVERAGE TAX DOCUMENTS.”

Timing matters too. For the 2025 tax year, the notice must be posted by March 2, 2026, and stay visible through October 15, 2026.² When an employee does request a copy, the form counts as timely if you provide it by the later of January 31 or 30 days after the request.

The savings on printing and postage can be substantial for a large workforce. The trap: an employer who stops the automatic mailings without posting a compliant notice hasn’t furnished anything at all, and the per-employee penalty applies.

2026 IRS Filing Deadlines

The alternative furnishing method changes only how you deal with employees. It doesn’t touch your filing obligation to the IRS, and those deadlines run on their own calendar. For the 2025 tax year:

Employee copies (if you mail them): the statutory January 31, 2026 deadline is automatically extended to March 2, 2026. No further extensions.³
Paper filing with the IRS: March 2, 2026 (the standard February 28 date shifts because it falls on a Saturday).
Electronic filing with the IRS: March 31, 2026.

If you’re using the website-notice approach, your notice still needs to be up by March 2, 2026.

Almost Everyone Has to File Electronically Now

The e-filing threshold was lowered in recent years to 10 information returns. If you file 10 or more information returns of any type during the calendar year, you must submit Forms 1094-C and 1095-C electronically through the IRS Affordable Care Act Information Returns (AIR) system.³ W-2s, 1099s, and 1095s all count toward that 10. In practice, essentially every ALE now hits the threshold and must e-file.

Using the AIR system isn’t something you can set up the week before the deadline. You need a Transmitter Control Code, which requires an ID.me account, access to IRS e-Services, and completion of the ACA Application for TCC.⁴ Your software also has to pass IRS communication test scenarios before it can submit live data. Most employers avoid this entirely by filing through a payroll provider or a third-party ACA vendor that already holds the credentials.

A hardship waiver exists under Form 8508, filed at least 45 days before the return due date, but it requires two current cost estimates from service bureaus showing that electronic filing would be genuinely unaffordable.⁵

What Skipping the Form Costs

Two separate penalty layers apply if you fail to file 1095-Cs correctly, and they can stack.

The first is the information return penalty under Sections 6721 and 6722. For returns due in 2026:⁶

$60 per form if corrected within 30 days of the deadline
$130 per form if corrected after 30 days but by August 1
$340 per form if filed after August 1 or not filed at all
$680 per form (or 10% of the total dollar amount required to be reported, whichever is greater) for intentional disregard, with no annual cap⁷

Section 6721 covers the IRS filing. Section 6722 covers the employee statement. Miss both for the same employee and the exposure doubles.⁸ An employer that ignores 1095-C reporting for 100 employees is looking at $68,000 in combined penalties before anything else happens. Errors count the same as missed filings: wrong Social Security numbers, incorrect coverage codes, and misreported premium amounts all trigger the same tiers.

The second layer is the employer shared responsibility payment under Section 4980H. The IRS uses your 1095-C data to determine whether these payments apply. If you don’t offer minimum essential coverage to at least 95% of your full-time employees and their dependents, and even one employee gets a premium tax credit through the marketplace, the 2026 penalty is $3,340 per full-time employee (with the first 30 excluded).⁹ If you do offer coverage but it’s unaffordable or fails to cover at least 60% of expected benefit costs, the penalty is $5,010 per full-time employee who actually receives subsidized marketplace coverage. These payments are not tax-deductible.

If you spot an error, move fast. The tiered structure rewards speed: the same mistake costs $60 per form fixed within 30 days and $340 per form fixed after August 1. Reasonable cause relief exists but is narrow. The IRS wants to see that you acted responsibly before and after the failure, and that either significant mitigating factors or circumstances beyond your control caused the problem.¹⁰ Not knowing about a decade-old filing obligation isn’t a winning argument.

Federal Filing Doesn’t Cover State Mandates

One boundary worth flagging. Several states plus the District of Columbia enforce their own individual health insurance mandates, and they run separate reporting regimes. Employers with staff in California, the District of Columbia, Massachusetts, New Jersey, Rhode Island, or Vermont typically must submit coverage data through state portals, often in a format that mirrors the federal 1095-C but with its own deadlines and penalties.

State fines accrue independently of federal amounts, so multi-state employers who assume the IRS filing takes care of everything can find themselves paying twice. Massachusetts is a particular one to watch because it uses its own form, the MA 1099-HC, rather than the federal 1095-C, with a January 31 furnishing date.

1
Internal Revenue Service. Affordable Care Act Tax Provisions for Employers
2
Internal Revenue Service. Instructions for Forms 1094-C and 1095-C (2025)
3
Internal Revenue Service. Instructions for Forms 1094-C and 1095-C (2025)
4
Internal Revenue Service. Apply for the Affordable Care Act for Transmitter Control Code (TCC)
5
Internal Revenue Service. Form 8508 – Application for a Waiver From Electronic Filing of Information Returns
6
Internal Revenue Service. Information Return Penalties
7
Office of the Law Revision Counsel. 26 USC 6721 – Failure to File Correct Information Returns
8
Office of the Law Revision Counsel. 26 USC 6722 – Failure to Furnish Correct Payee Statements
9
Internal Revenue Service. Questions and Answers on Employer Shared Responsibility Provisions Under the Affordable Care Act
10
Internal Revenue Service. Penalty Relief for Reasonable Cause