Form 1094-C is a transmittal form that certain employers must file with the IRS to report compliance with the Affordable Care Act (ACA). It acts as a cover sheet that summarizes the information provided in Form 1095-C, which details health coverage offered to individual employees.
In simple terms: 1094-C = Employer summary, while 1095-C = Employee-specific details.
Employers preparing ACA filings often rely on accurate payroll data like Regular Hours and employee headcount, since these directly affect reporting.
What is Form 1094-C Used For?
The IRS uses Form 1094-C to:
- Track whether large employers (50+ full-time employees) are meeting ACA coverage requirements.
- Verify that employees were offered affordable health insurance.
- Confirm reporting consistency across Form 1095-C filings.
Without filing 1094-C, employers may face compliance penalties.
Who Must File Form 1094-C?
Form 1094-C must be filed by:
- Applicable Large Employers (ALEs): Generally, employers with 50 or more full-time employees (including full-time equivalents).
- ALEs that sponsor self-insured health plans must file both 1094-C and 1095-C for covered employees.
Employers often also prepare tax-related forms like 1099 NEC Form or 1099 MISC Form for contractors—so keeping payroll records accurate is crucial.
How to Fill Out Form 1094-C?
The form has several sections:
- Part I – Employer Information
- Part II – ALE Member Information
- Part III – ALE Member Information (Monthly)
- Part IV – Aggregated ALE Group Information
Because of its complexity, most businesses use payroll providers or HR software to ensure accuracy. Having clear records of Accrued Leave and work schedules makes this process easier.
Key Deadlines: When is Form 1094-C Due?
- Paper Filing: By February 28, 2025
- Electronic Filing: By March 31, 2025
- Employee Copies (1095-C): Must be furnished by March 3, 2025
Deadlines often align with payroll cycles and important dates like Federal Holidays 2025 and Federal Holidays 2026, so employers should plan ahead.
Form 1094-C vs Form 1095-C
| Feature | Form 1094-C | Form 1095-C |
| Purpose | Summarizes employer ACA compliance | Reports coverage offered to each employee |
| Filed With | IRS only | IRS + employee copies |
| Who Files | Applicable Large Employers (ALEs) | Same ALEs, for each covered employee |
Why Does This Matter for Payroll?
Although 1094-C is health insurance reporting, it directly ties into payroll since employee headcount and hours determine ACA compliance.
For example, contributions to retirement plans like a 401a Plan, 401k Contribution, or Roth IRA often show up in payroll records and can affect what employers report.
FAQs: Form 1094-C
Q1. What is Form 1094-C?
Form 1094-C is an IRS transmittal form that large employers file to report compliance with the Affordable Care Act (ACA). It summarizes the information provided in Form 1095-C for employees.
Q2. Who must file Form 1094-C?
Applicable Large Employers (ALEs) with 50 or more full-time employees, including full-time equivalents, must file Form 1094-C. ALEs that sponsor self-insured health plans also must file Form 1095-C for employees.
Q3. What is the purpose of Form 1094-C?
The form helps the IRS track ACA compliance, verify that employees were offered affordable health coverage, and ensure consistency across Form 1095-C filings.
Q4. How does Form 1094-C differ from Form 1095-C?
Form 1094-C is employer-level (summary) reporting, while Form 1095-C provides employee-specific health coverage details.
Q5. When is Form 1094-C due?
- Paper filing: February 28, 2025
- Electronic filing: March 31, 2025
- Employee copies (Form 1095-C) must be furnished by March 3, 2025.
Q6. What sections are on Form 1094-C?
- Part I – Employer Information
- Part II – ALE Member Information
- Part III – ALE Member Information (Monthly)
- Part IV – Aggregated ALE Group Information
Q7. Can payroll data affect Form 1094-C filings?
Yes. Employee headcount, regular hours, and other payroll information directly impact ACA reporting and compliance calculations.
Q8. What happens if an employer fails to file Form 1094-C?
Employers may face IRS penalties for non-compliance, including fines for failing to report ACA coverage accurately.
Q9. Can software help with Form 1094-C?
Yes. Payroll providers and HR software help employers accurately track hours, headcount, and health coverage data, simplifying ACA filings.
Q.10. How is Form 1094-C related to payroll compliance?
Payroll compliance includes ACA reporting. Accurate payroll records ensure correct reporting of employee hours, benefits, and health coverage, which are essential for Form 1094-C filings.
Key Takeaways
- Form 1094-C is the employer-level ACA transmittal form filed with the IRS.
- It works alongside Form 1095-C, which goes to employees.
- Deadlines vary for paper vs electronic filing.
- Only large employers (50+ employees) are required to file.
- Payroll and HR systems play a big role in compliance reporting.
Payroll compliance goes beyond paychecks, it also means staying on top of reporting like ACA forms. With StubBuilder’s online paycheck stub generator, you can simplify payroll records and ensure employee information is accurate, making it easier when it’s time to file forms like 1094-C.
