The Form 1095-C due date depends on how you file: paper returns are due February 28 and electronic returns March 31 of the year following the reporting period. For tax year 2025 returns, February 28, 2026 falls on a Saturday, so the paper deadline moves to Monday, March 2, 2026, while the electronic deadline stays at March 31, 2026. A separate deadline governs getting the form to employees, and that side of the obligation changed recently: employers can now post a website notice offering copies on request instead of automatically mailing every full-time employee.
IRS Filing Deadlines for Tax Year 2025
The submission method sets your deadline with the IRS.
- Paper filing: February 28 of the year after the reporting period. For tax year 2025, that lands on a Saturday, so the deadline shifts to Monday, March 2, 2026.
- Electronic filing: March 31 of the year after the reporting period. For tax year 2025, that is March 31, 2026.
When a deadline lands on a weekend or federal holiday, it rolls to the next business day. Form 1094-C, the transmittal that accompanies your batch of 1095-Cs, follows the same dates.
Electronic Filing Is Mandatory for Most ALEs
If your organization files 10 or more information returns of any type during a calendar year, all of them must be submitted electronically. The threshold aggregates across return types, so W-2s, 1099s, and 1094-C/1095-C forms all count together.1Internal Revenue Service. Topic No. 801, Who Must File Information Returns Electronically The statute set this 10-return threshold for calendar years after 2021.2Office of the Law Revision Counsel. 26 USC 6011 – Return Requirements
Because an Applicable Large Employer by definition has at least 50 full-time employees, virtually every ALE crosses that threshold and must file electronically. The IRS processes 1095-C submissions through its ACA Information Returns (AIR) system, not the FIRE system used for most other information returns.1Internal Revenue Service. Topic No. 801, Who Must File Information Returns Electronically
The Employee Furnishing Deadline
Getting Form 1095-C to employees is a separate obligation with its own timeline. Starting with tax year 2024 forms, the Paperwork Burden Reduction Act let employers stop mass-mailing the form. You now satisfy the furnishing requirement by posting a clear, conspicuous, and accessible notice on your website telling employees they can request a copy.3Internal Revenue Service. Instructions for Forms 1094-C and 1095-C (Draft)
Under the website-notice method, a requested copy is timely if you provide it by the later of January 31 of the following year or 30 days after the employee’s request.3Internal Revenue Service. Instructions for Forms 1094-C and 1095-C (Draft) The notice itself has to stay on your website through October 15 of the year following the reporting period. For tax year 2025, the notice must remain live until October 15, 2026.
You can still furnish forms directly if you prefer. In that case, forms should be postmarked, hand-delivered, or electronically delivered by January 31. Email delivery requires prior consent from the employee.
Requesting an Extension
If you need more time to file with the IRS, submit Form 8809 (Application for Extension of Time to File Information Returns) before the original due date. A timely Form 8809 automatically grants a 30-day extension with no justification required.4Internal Revenue Service. Form 8809 – Application for Extension of Time to File Information Returns You can submit it electronically through the IRS FIRE system.5Internal Revenue Service. About Form 8809, Application for Extension of Time to File Information Returns
A second 30-day extension is available but not automatic. You have to give a written explanation, and the IRS can deny it.4Internal Revenue Service. Form 8809 – Application for Extension of Time to File Information Returns Genuine barriers like a system migration or vendor failure tend to succeed; vague requests usually don’t.
Form 8809 extends only the IRS filing deadline. It does not extend the furnishing deadline, though the website-notice alternative has effectively loosened that timeline for most employers.
Penalties for Missing the Due Date
Penalties apply separately to two failures: not filing correct returns with the IRS (Section 6721) and not furnishing correct statements to employees (Section 6722). Miss both for the same employee and each obligation gets penalized independently.
Per-Return Amounts for 2026
The IRS adjusts these annually. For returns and statements due in 2026:6Internal Revenue Service. Information Return Penalties
- Corrected within 30 days of the due date: $60 per return
- Corrected after 30 days but on or before August 1: $130 per return
- Filed after August 1 or not filed at all: $340 per return
- Intentional disregard: the greater of $690 per return or 10% of the total amounts required to be reported, with no annual cap
The tiered structure rewards speed. Catch a problem in February and file corrections within 30 days, and you pay $60 per return instead of $340. For 500 employees, that’s a $140,000 swing.
Annual Caps
For employers with average annual gross receipts above $5 million over the three most recent tax years:7Internal Revenue Service. Rev. Proc. 2025-32
- Corrected within 30 days: $698,500 per year
- Corrected by August 1: $2,095,500 per year
- After August 1 or never filed: $4,191,500 per year
Employers with average annual gross receipts of $5 million or less get lower caps:7Internal Revenue Service. Rev. Proc. 2025-32
- Corrected within 30 days: $244,500 per year
- Corrected by August 1: $698,500 per year
- After August 1 or never filed: $1,397,000 per year
Reasonable Cause Relief
The IRS can waive penalties if you show reasonable cause. It’s not a blanket safe harbor; each case is evaluated on its facts. You have to demonstrate two things: that you acted responsibly before and after the failure, and that significant mitigating factors contributed to it.8Internal Revenue Service. Penalty Relief for Reasonable Cause
Acting responsibly means you requested extensions when you could, tried to prevent foreseeable problems, and fixed the failure quickly once you found it. Mitigating factors include being a first-time filer, having a strong compliance history, a third-party vendor system failure, or circumstances genuinely beyond your control.8Internal Revenue Service. Penalty Relief for Reasonable Cause
To request relief, call the number on your IRS penalty notice with the notice, a description of the penalty you want removed, your reasons, and supporting documentation ready. If the IRS can’t resolve it by phone, you can submit a written request on Form 843 (Claim for Refund and Request for Abatement). “We didn’t know we had to file” is not a winning argument. “Our payroll vendor’s system crashed two weeks before the deadline and we filed corrected returns within 10 days of getting access back” is the kind of explanation that actually works.