Form 1094-B: Filing Requirements, Deadlines, and Corrections

Form 1094-B is the one-page IRS transmittal that accompanies a batch of Forms 1095-B, summarizing how many individual health coverage statements you are sending in. It collects only your organization’s identifying information and a total count of the attached 1095-B forms. You file it if you provided minimum essential coverage during the calendar year and you are not an Applicable Large Employer.

Who Has to File Form 1094-B

Federal law requires every person or entity that provides minimum essential coverage during a calendar year to file an information return with the IRS.¹ The 1094-B/1095-B series is for filers that are not Applicable Large Employers. An Applicable Large Employer (ALE) is any organization that averaged 50 or more full-time employees, counting full-time equivalents, during the prior calendar year. ALEs use the 1094-C/1095-C series instead, regardless of plan type.²

The most common 1094-B filers are:

Small employers (fewer than 50 full-time employees) that sponsor a self-insured health plan and report coverage for all enrolled individuals.
Health insurance issuers and carriers reporting the fully insured coverage they sold.
Government programs administering Medicaid, Medicare, CHIP, and similar coverage.

If you are not sure whether your organization is an ALE, resolve that question before doing anything else. It determines which form series you use for every downstream step.

Completing the Form Line by Line

Form 1094-B is short. Every field is either identification or a summary count; no individual-level coverage data goes on this form.

Lines 1 and 2: your organization’s full legal name and nine-digit Employer Identification Number (EIN). Both must match exactly what the IRS has on file for the entity.
Lines 3 and 4: the name and telephone number of a contact person who can respond to IRS inquiries about the submission.
Lines 5 through 8: the complete mailing address where the IRS should send correspondence. A P.O. box is acceptable if that is where your mail goes.²
Line 9: the total number of Forms 1095-B transmitted with this 1094-B. The count must exactly match the number of individual statements in the batch.²

Line 9 is where mistakes tend to happen, especially when multiple batches go out or when last-minute additions come in. Verify the count against your actual stack of 1095-B forms before submitting. Electronic filing software will usually calculate it for you, but check anyway.

Filing Deadlines

IRS filing deadlines for Form 1094-B and its attached 1095-B forms depend on how you file.²

Paper filing: February 28 of the year following coverage.
Electronic filing: March 31 of the year following coverage.

If either date falls on a weekend or federal holiday, the deadline moves to the next business day.

A separate obligation runs alongside the IRS deadline: you must furnish a written statement (a copy of the 1095-B) to every individual listed on a Form 1095-B by March 2 of the year following coverage.¹ For the 2025 coverage year, recipient copies are due by March 2, 2026. Missing this deadline carries its own penalties, structured the same way as the IRS filing penalties.

Extension With Form 8809

You can get an automatic 30-day extension of the IRS filing deadline by submitting Form 8809 on or before the original due date.³ Form 8809 can be filed online through the FIRE system. The extension applies only to filing with the IRS. It does not push back the March 2 deadline for furnishing statements to covered individuals.

Electronic Filing Requirements

The IRS requires electronic filing from any entity that submits 10 or more information returns in a calendar year. The threshold counts all your information returns in aggregate (W-2s, 1099s, and everything else), not just the 1094-B/1095-B series.² In practice, almost any organization filing 1094-B will cross that line.

Electronic submission goes through the IRS Affordable Care Act Information Returns (AIR) system. First-time filers must apply for an ACA Transmitter Control Code (TCC) before using the system.⁴ The application requires an ID.me account to access e-Services; once your application is complete, the TCC is visible online and also mailed to you.⁵ Start early. Registration, software testing, and approval all take time.

Waiver From Electronic Filing

If electronic filing creates a genuine hardship, you can request a waiver by submitting Form 8508 to the IRS at least 45 days before the return due date.⁶ Acceptable reasons include undue financial hardship (where the cost of e-filing exceeds paper filing), a federally declared disaster affecting your business, or your first year of operation. A financial hardship claim must include two written cost estimates comparing electronic and paper filing; the IRS automatically denies requests that lack them. Filing on paper without an approved waiver draws the same penalties as filing late.

Paper Filing Addresses

If you qualify to file on paper, mail your completed Form 1094-B along with all attached 1095-B forms to the IRS service center assigned to your location.²

Austin, TX 73301: for filers in Alabama, Arizona, Arkansas, Connecticut, Delaware, Florida, Georgia, Kentucky, Louisiana, Maine, Massachusetts, Mississippi, New Hampshire, New Jersey, New Mexico, New York, North Carolina, Ohio, Pennsylvania, Rhode Island, Texas, Vermont, Virginia, or West Virginia.
Kansas City, MO 64121-9256 (P.O. Box 219256): for filers in all other states and the District of Columbia.

Filers located outside the United States send returns to the Austin address.

Filing Corrected Returns

When an error turns up on a Form 1095-B that has already been filed, submit a corrected version. Complete a full, correct Form 1095-B, mark an “X” in the “CORRECTED” checkbox, and transmit it with a new Form 1094-B. You do not file a corrected Form 1094-B itself; use a fresh transmittal for the corrected 1095-B forms.² You must also furnish a corrected copy to the individual who received the original statement.

Retroactive coverage changes after you have filed trigger the same correction requirement. Retroactive enrollment adjustments and COBRA elections that backdate coverage are common triggers.

Penalties for Late or Incorrect Filing

The IRS assesses penalties per return for failing to file correct information returns on time, and separately for failing to furnish correct statements to recipients. For returns due in 2026, the per-return amounts are:⁷

Filed up to 30 days late: $60 per return.
Filed 31 days late through August 1: $130 per return.
Filed after August 1 or not filed at all: $340 per return.
Intentional disregard: $680 per return, with no annual maximum.

Annual caps limit the total penalty for every tier except intentional disregard, and the caps depend on organization size. Filers with average annual gross receipts of $5 million or less face maximums of $239,000 (30-day tier), $683,000 (August 1 tier), and $1,366,000 (after August 1). Larger organizations face maximums of $683,000, $2,049,000, and $4,098,500 at the same tiers.⁸ The tier structure rewards fast action. If you realize a deadline has slipped, filing within 30 days keeps your per-return exposure at the lowest rate.

Reasonable Cause Relief

The IRS can waive penalties in full if you show the failure was due to reasonable cause and not willful neglect.⁹ The standard asks whether you exercised ordinary business care and prudence but still could not comply. Circumstances the IRS will consider include natural disasters, destruction of records, serious illness or death of the person responsible for filing, and reliance on erroneous IRS advice. Not knowing about the requirement, or being short on funds, is generally not enough on its own.

1
Office of the Law Revision Counsel. 26 USC 6055 – Reporting of Health Insurance Coverage
2
Internal Revenue Service. Instructions for Forms 1094-B and 1095-B
3
Internal Revenue Service. About Form 8809, Application for Extension of Time to File Information Returns
4
Internal Revenue Service. Affordable Care Act Information Returns (AIR)
5
Internal Revenue Service. Apply for the Affordable Care Act for Transmitter Control Code (TCC)
6
Internal Revenue Service. Form 8508, Application for a Waiver from Electronic Filing of Information Returns
7
Internal Revenue Service. Information Return Penalties
8
Internal Revenue Service. 20.1.7 Information Return Penalties
9
Office of the Law Revision Counsel. 26 USC 6724 – Waiver; Definitions and Special Rules