Instructions for Forms

2025

Instructions for Forms

1094-C and 1095-C

Section references are to the Internal Revenue Code

unless otherwise noted.

Future Developments

For the latest information about developments related to

Form 1094-C, Transmittal of Employer-Provided Health

Insurance Offer and Coverage Information Returns, and

Form 1095-C, Employer-Provided Health Insurance Offer

and Coverage, and the instructions, such as legislation

enacted after they were published, go to IRS.gov/

Form1094C and IRS.gov/Form1095C.

What’s New

Alternative manner of furnishing statements.

Employers no longer have to automatically send Form

1095-C to individuals. The requirement for furnishing the

statement is met if the employer responsible for providing

the statements provides clear, conspicuous, and

accessible notice on its website that an individual may

request a copy of their statement and the copy is timely

furnished. For this purpose, the statement is timely

furnished if provided to the individual no later than the

later of January 31, 2026, or 30 days after the date of the

request. For additional guidance, see IRS.gov/irb/

2025-11_IRB#NOT-2025-15.

Additional Information

For information related to the Affordable Care Act, visit

IRS.gov/ACA. For the final regulations under section 6056,

Information Reporting by Applicable Large Employers on

Health Insurance Coverage Offered Under

Employer-Sponsored Plans, see T.D. 9661, 2014-13 I.R.B.

855, at IRS.gov/irb/2014-13_IRB#TD-9661. For the final

regulations under section 6055, Information Reporting of

Minimum Essential Coverage, see T.D. 9660, 2014-13

I.R.B. 842, at IRS.gov/irb/2014-13_IRB#TD-9660 and T.D.

9970, 2023-02 I.R.B. 311, at IRS.gov/irb/2023–

02_IRB#TD-9970. For the final regulations under section

4980H, Shared Responsibility for Employers Regarding

Health Coverage, see T.D. 9655, 2014-9 I.R.B. 541, at

IRS.gov/irb/2014-09_IRB#TD-9655. For answers to

frequently asked questions regarding the employer shared

responsibility provisions and related information reporting

requirements, visit IRS.gov.

For information related to filing Forms 1094-C and

1095-C electronically, visit IRS.gov/AIR. For FAQs

specifically related to completing Forms 1094-C and

1095-C, go to IRS.gov/Affordable-Care-Act/Employers/

Questions-and-Answers-about-Information-Reporting-byEmployers-on-Form-1094-C-and-Form-1095-C.

For additional guidance and proposed regulatory

changes relating to section 6055, including the

requirement to solicit the TIN of each covered individual

Oct 30, 2025

for purposes of the reporting of health coverage

information, see Proposed Regulations section

1.6055-1(h) and Regulations section 301.6724-1.

General Instructions for Forms

1094-C and 1095-C

See Definitions, later, for key terms used in these

instructions.

Purpose of Form

Employers with 50 or more full-time employees (including

full-time equivalent employees) in the previous year use

Forms 1094-C and 1095-C to report the information

required under sections 6055 and 6056 about offers of

health coverage and enrollment in health coverage for

their employees. Form 1094-C must be used to report to

the IRS summary information for each Applicable Large

Employer (ALE Member) (defined below) and to transmit

Forms 1095-C to the IRS. Form 1095-C is used to report

information about each employee to the IRS and to the

employee. Forms 1094-C and 1095-C are used in

determining whether an ALE Member owes a payment

under the employer shared responsibility provisions under

section 4980H. Form 1095-C is also used in determining

the eligibility of employees for the premium tax credit.

ALE Members that offer employer-sponsored,

self-insured coverage also use Form 1095-C to report

information to the IRS and to employees about individuals

who have minimum essential coverage under the

employer plan.

Who Must File

An ALE Member must file one or more Forms 1094-C

(including a Form 1094-C designated as the Authoritative

Transmittal, whether or not filing multiple Forms 1094-C),

and must file a Form 1095-C for each employee who was

a full-time employee of the ALE Member for any month of

the calendar year. Generally, the ALE Member is required

to furnish a copy of the Form 1095-C (or a substitute form)

to the employee.

An ALE Member is, generally, a single person or entity

that is an Applicable Large Employer, or if applicable,

each person or entity that is a member of an Aggregated

ALE Group. An Applicable Large Employer, generally, is

an employer with 50 or more full-time employees

(including full-time equivalent employees) in the previous

year. For purposes of determining if an employer or group

of employers is an Applicable Large Employer, all ALE

Members under common control (an Aggregated ALE

Group) are aggregated together. If the Aggregated ALE

Group, taking into account the employees of all ALE

Members in the group, employed on average 50 or more

Instructions for Form 1094-C and Form 1095-C (2025) Catalog Number 63018M

Department of the Treasury Internal Revenue Service www.irs.gov

full-time employees (including full-time equivalent

employees) on business days during the preceding

calendar year, then the Aggregated ALE Group is an

Applicable Large Employer and each separate employer

within the group is an ALE Member. Each ALE Member is

required to file Forms 1094-C and 1095-C reporting offers

of coverage to its full-time employees (even if the ALE

Member has fewer than 50 full-time employees of its own).

For more information on which employers are subject to

the employer shared responsibility provisions of section

4980H, see Employer in the Definitions section of these

instructions. For more information on determining full-time

employees, see Full-Time Employee in the Definitions

section of these instructions, which includes information

on the treatment of new hires and employees in Limited

Non-Assessment Periods.

Tip: For purposes of reporting on Forms 1094-C and

1095-C, an employee in a Limited Non-Assessment

Period is not considered a full-time employee during that

period.

Reporting by Employers That

Sponsor Self-Insured Health Plans

An employer that offers health coverage through a

self-insured health plan must report information about

each individual enrolled in such coverage. For an

employer that is an ALE Member, this information must be

reported on Form 1095-C, Part III, for any employee who is

enrolled in coverage (and any spouse or dependent of

that employee). See the option to file Form 1094-B and

Form 1095-B, rather than Form 1094-C and Form 1095-C,

to report coverage of certain nonemployees, below.

ALE Members that offer health coverage through an

employer-sponsored, self-insured health plan must

complete Form 1095-C, Parts I, II, and III, for any

employee who enrolls in the health coverage, whether or

not the employee is a full-time employee for any month of

the calendar year.

An employer that offers employer-sponsored,

self-insured health coverage but is not an ALE Member

should not file Forms 1094-C and 1095-C, but should

instead file Forms 1094-B and 1095-B to report

information for employees who enrolled in the

employer-sponsored, self-insured health coverage.

Note: If an ALE Member is offering health coverage to

employees other than under a self-insured plan, such as

through an insured health plan or a multiemployer health

plan, the issuer of the insurance or the sponsor of the plan

providing the coverage is required to furnish the

information about their health coverage to any enrolled

employees, and the ALE Member should not complete

Form 1095-C, Part III, for those employees.

Reporting of Enrollment Information for

Nonemployees: Option To Use Forms 1094-B and

1095-B

ALE Members that offer employer-sponsored, self-insured

health coverage to nonemployees who enroll in the

coverage may use Forms 1094-B and 1095-B, rather than

Form 1095-C, Part III, to report coverage for those

individuals and other family members. For this purpose, a

nonemployee includes, for example, a nonemployee

director, an individual who was a retired employee during

the entire year, or a nonemployee COBRA beneficiary,

including a former employee who terminated employment

during a previous year.

For information on reporting for nonemployees enrolled

in an employer-sponsored, self-insured health plan using

Forms 1094-B and 1095-B, see the instructions for those

forms.

For ALE Members that choose to use Form 1095-C to

report coverage information for nonemployees enrolled in

an employer-sponsored, self-insured health plan, see the

specific instructions for Form 1095-C, Part III—Covered

Individuals (Lines 18–30), later. Form 1095-C may be

used only if the individual identified on line 1 has an SSN.

For full-time employees enrolled in an ALE Member’s

self-insured coverage, including an employee who was a

full-time employee for at least 1 month of the calendar

year, the ALE Member must complete Form 1095-C, Part

II, according to the generally applicable instructions, and

should not enter code 1G on line 14 for any month. For an

employee enrolled in an ALE Member’s self-insured

coverage who is not a full-time employee for any month of

the calendar year (meaning that for all 12 calendar months

the employee was not a full-time employee), for Form

1095-C, Part II, the ALE Member must enter code 1G on

line 14 in the “All 12 Months” column or in the separate

monthly boxes for all 12 calendar months, and the ALE

Member need not complete Part II, lines 15 and 16.

If you are not using the official IRS form to furnish

statements to recipients, see Pub. 5223, General Rules

and Specifications for Affordable Care Act Substitute

Forms 1095-A, 1094-B, 1095-B, 1094-C, and 1095-C,

which explains the requirements for format and content of

substitute statements to recipients. You may develop them

yourself or buy them from a private printer. Substitute

statements furnished to recipients may be in portrait

format; however, substitute returns filed with the IRS using

paper must be printed in landscape format.

Tip: An individual coverage HRA is a self-insured group

health plan and is therefore an eligible

employer-sponsored plan. An individual is ineligible for a

premium tax credit (PTC) for a month if the individual is

covered by an individual coverage HRA or eligible for an

individual coverage HRA that is affordable.

A Form 1094-C must be filed when an ALE Member files

one or more Forms 1095-C. An ALE Member may choose

to file multiple Forms 1094-C, each accompanied by

Forms 1095-C for a portion of its employees, provided that

a Form 1095-C is filed for each employee for whom the

ALE Member is required to file. If an ALE Member files

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Substitute Statements to Recipients

Authoritative Transmittal for ALE Members

Filing Multiple Forms 1094-C

Instructions for Forms 1094-C and 1095-C (2025)

more than one Form 1094-C, one (and only one) Form

1094-C filed by the ALE Member must be identified on

line 19, Part I, as the Authoritative Transmittal, and, on the

Authoritative Transmittal, the ALE Member must report

certain aggregate data for all full-time employees and all

employees, as applicable, of the ALE Member.

Example 1. Employer A, an ALE Member, files a

single Form 1094-C, attaching Forms 1095-C for each of

its 100 full-time employees. This Form 1094-C should be

identified as the Authoritative Transmittal on line 19, and

the remainder of the form completed as indicated in the

instructions for line 19, later.

Example 2. Employer B, an ALE Member, files two

Forms 1094-C, one for each of its two operating divisions,

Division X and Division Y. (Division X and Division Y are

units of the same ALE Member, and thus both report

under the same employer identification number (EIN);

they are not members of an Aggregated ALE Group.)

Attached to one Form 1094-C are Forms 1095-C for the

200 full-time employees of Division X, and attached to the

other Form 1094-C are Forms 1095-C for the 1,000

full-time employees of Division Y. One of these Forms

1094-C should be identified as the Authoritative

Transmittal on line 19, and should include aggregate

employer-level data for all 1,200 full-time employees of

Employer B as well as the total number of employees of

Employer B, as applicable, as required in Parts II, III, and

IV of Form 1094-C. The other Form 1094-C should not be

identified as the Authoritative Transmittal on line 19, and

should report on line 18 only the number of Forms 1095-C

that are attached to that Form 1094-C, and should leave

the remaining sections of the form blank, as indicated in

the instructions for line 19, later.

Note: Each ALE Member must file its own Forms 1094-C

and 1095-C under its own separate EIN, even if the ALE

Member is part of an Aggregated ALE Group. No

Authoritative Transmittal should be filed for an Aggregated

ALE Group.

Example 3. Assume that Employer A from Example 1

is a member of the same Aggregated ALE Group as

Employer B from Example 2. Accordingly, Employer A and

Employer B are separate ALE Members filing under

separate EINs. Forms 1094-C should be filed in the same

manner indicated in Examples 1 and 2. Employer A

should include only information about employees of

Employer A in its Authoritative Transmittal, and Employer

B should include only information about employees of

Employer B in its Authoritative Transmittal. No

Authoritative Transmittal should be filed for the

Aggregated ALE Group reporting combined data for

employees of both Employer A and Employer B.

Similar rules apply for a Governmental Unit that has

delegated its reporting responsibilities for some of its

employees to another Governmental Unit—see

Designated Governmental Entity (DGE) in the Definitions

section of these instructions for more information. In the

case of a Governmental Unit that has delegated its

reporting responsibilities for some of its employees, the

Governmental Unit must ensure that among the multiple

Forms 1094-C filed by or on behalf of the Governmental

Unit transmitting Forms 1095-C for the Governmental

Instructions for Forms 1094-C and 1095-C (2025)

Unit’s employees, one of the filed Forms 1094-C is

designated as the Authoritative Transmittal and reports

aggregate employer-level data for the Governmental Unit,

as required in Parts II, III, and IV of Form 1094-C.

Example. County is an Aggregated ALE Group made

up of the ALE Members School District, the Police District,

and the County General Office. The School District

designates the state to report on behalf of the teachers

and reports for itself for its remaining full-time employees.

In this case, either the School District or the state must file

an Authoritative Transmittal reporting aggregate

employer-level data for the School District.

One Form 1095-C for Each Employee of ALE

Member

For each full-time employee of an ALE Member, there

must be only one Form 1095-C filed for employment with

that ALE Member. For example, if an ALE Member

separately reports for each of its two divisions, the ALE

Member must combine the offer and coverage information

for any employee who worked at both divisions during the

calendar year so that a single Form 1095-C is filed for the

calendar year for that employee, which reports information

for all 12 months of the calendar year from that ALE

Member.

In contrast, a full-time employee who works for more

than one ALE Member that is a member of the same

Aggregated ALE Group must receive a separate Form

1095-C from each ALE Member. For any calendar month

in which a full-time employee works for more than one

ALE Member of an Aggregated ALE Group, only one ALE

Member is treated as the employer of that employee for

reporting purposes (generally, the ALE Member for whom

the employee worked the greatest number of hours of

service), and only that ALE Member reports for that

employee for that calendar month. The other ALE Member

is not required to report for that employee for that calendar

month, unless the other ALE Member is otherwise

required to file Form 1095-C for that employee because

the individual was a full-time employee of that ALE

Member for a different month of the same calendar year.

In this case, the individual may be treated as not

employed by that ALE Member for that calendar month. If

under these rules, an ALE Member is not required to

report for an employee for any month in the calendar year,

the ALE Member is not required to report for that full-time

employee for that calendar year. For a description of the

rules related to determining which ALE Member in an

Aggregated ALE Group is treated as the employer for a

month in this situation, see the definition of Employee.

Example. Employer A and Employer B are separate

ALE Members that belong to the same Aggregated ALE

Group. Both Employer A and Employer B offer coverage

through the AB health plan, which is an insured plan. In

January and February, Employee has 130 hours of service

for Employer A and no hours of service for Employer B. In

March, Employee has 100 hours of service for Employer A

and 30 hours of service for Employer B. In April through

December, Employee has 130 hours of service for

Employer B and no hours of service for Employer A.

Employer A is the employer of Employee for filing

purposes for January, February, and March. Employer A

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should file Form 1095-C for Employee reporting offers of

coverage using the appropriate code on line 14 for

January, February, and March; should complete lines 15

and 16 per the instructions; and should include Employee

in the count of total employees and full-time employees

reported for those months on Form 1094-C. For the

months April through December, on Form 1095-C,

Employer A should enter code 1H (no offer of coverage)

on line 14, leave line 15 blank, and enter code 2A (not an

employee) on line 16 (since Employee is treated as an

employee of Employer B and not as an employee of

Employer A in those months), and should exclude

Employee from the count of total employees and full-time

employees reported for those months on Form 1094-C.

When To File

You will meet the requirement to file Forms 1094-C and

1095-C if the forms are properly addressed and mailed on

or before the due date. If the due date falls on a weekend

or legal holiday, then the due date is the following

business day. A business day is any day that is not a

Saturday, Sunday, or legal holiday.

Generally, you must file Forms 1094-C and 1095-C by

February 28 if filing on paper (or March 31 if filing

electronically) of the year following the calendar year to

which the return relates. For calendar year 2025, Forms

1094-C and 1095-C are required to be filed by March 2,

2026, or March 31, 2026, if filing electronically.

See Furnishing Forms 1095-C to Employees for

information on when Form 1095-C must be furnished.

Extensions

You can get an automatic 30-day extension of time to file

by completing Form 8809, Application for Extension of

Time To File Information Returns. The form may be

submitted on paper, or through the FIRE System either as

a fill-in form or an electronic file. No signature or

explanation is required for the extension. However, you

must file Form 8809 on or before the due date of the

returns in order to get the 30-day extension. Under certain

hardship conditions, you may apply for an additional

30-day extension. See the Instructions for Form 8809 for

more information.

How to apply. File Form 8809 as soon as you know that

a 30-day extension of time to file is needed. See the

instructions for Form 8809. Mail or fax Form 8809 using

the address and phone number listed in the instructions.

You can also submit the extension request online through

the FIRE System. You are encouraged to submit requests

using the online fill-in form. See Pub. 1220 for more

information on filing online or electronically.

Where To File

Send all information returns filed on paper to the following:

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If your principal business,

office or agency, or legal

residence, in the case of an

individual, is located 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,

West Virginia

If your principal business,

office or agency, or legal

residence, in the case of an

individual, is located in:

▼

Alaska, California, Colorado,

District of Columbia, Hawaii,

Idaho, Illinois, Indiana, Iowa,

Kansas, Maryland, Michigan,

Minnesota, Missouri, Montana,

Nebraska, Nevada, North

Dakota, Oklahoma, Oregon,

South Carolina, South Dakota,

Tennessee, Utah, Washington,

Wisconsin, Wyoming

Use the following address:

▼

Department of the Treasury

Internal Revenue Service

Center

Austin, TX 73301

Use the following address:

▼

Department of the Treasury

Internal Revenue Service

Center

P.O. Box 219256

Kansas City, MO 64121-9256

If your legal residence or principal place of business or

principal office or agency is outside the United States, file

with the Department of the Treasury, Internal Revenue

Service Center, Austin, TX 73301.

Shipping and mailing. If you are filing on paper, send

the forms to the IRS in a flat mailing (not folded), and do

not paperclip or staple the forms together. If you are

sending many forms, you may send them in conveniently

sized packages. On each package, write your name,

number the packages consecutively, and place Form

1094-C in package number one. Postal regulations require

forms and packages to be sent by First-Class Mail.

Returns filed with the IRS must be printed in landscape

format.

Keeping copies. Generally, keep copies of information

returns you filed with the IRS or have the ability to

reconstruct the data for at least 3 years, from the due date

of the returns.

Electronic Filing

If you are required to file 10 or more

information returns during the year, you

must file the forms electronically. The

10-or-more requirement applies in the aggregate to

certain information returns. Accordingly, a filer may be

required to file fewer than 10 Forms 1094-C and 1095-C,

but still have an electronic filing obligation based on other

Instructions for Forms 1094-C and 1095-C (2025)

kinds of information returns filed. The electronic filing

requirement does not apply if you request and receive a

hardship waiver. The IRS encourages you to file

electronically even though you are filing fewer than 10

returns.

Waiver. To receive a waiver from the required filing of

information returns electronically, submit Form 8508. You

are encouraged to file Form 8508 at least 45 days before

the due date of the returns, but no later than the due date

of the return. The IRS does not process waiver requests

until January 1 of the calendar year the returns are due.

You cannot apply for a waiver for more than 1 tax year at a

time. If you need a waiver for more than 1 tax year, you

must reapply at the appropriate time each year. If a waiver

for original returns is approved, any corrections for the

same types of returns will be covered under the waiver.

However, if you submit original returns electronically but

you want to submit your corrections on paper, a waiver

must be approved for the corrections if you must file 10 or

more corrections. If you receive an approved waiver, do

not send a copy of it to the service center where you file

your paper returns. Keep the waiver for your records only.

If you are required to file electronically but fail to do so,

and you do not have an approved waiver, you may be

subject to a penalty of $340 per return for failure to file

electronically unless you establish reasonable cause.

However, you can file up to 10 returns on paper; those

returns will not be subject to a penalty for failure to file

electronically.

Pub. 5165, Guide for Electronically Filing Affordable

Care Act (ACA) Information Returns for Software

Developers and Transmitters, specifies the

communication procedures, transmission formats,

business rules, and validation procedures, and explains

when a return will be accepted, accepted with errors, or

rejected, for returns filed electronically for calendar year

2025 through the ACA Information Return (AIR) system.

To develop software for use with the AIR system, software

developers, transmitters, and issuers, including ALE

Members filing their own Forms 1094-C and 1095-C,

should use the guidelines provided in Pub. 5165 along

with the Extensible Markup Language (XML) Schemas

published on IRS.gov.

Reminder. The formatting directions in these

instructions (for example, the directions to enter the

nine-digit EIN, including the dash on line 2 of Form

1094-C) are for the preparation of paper returns. When

filing forms electronically, the formatting set forth in the

XML Schemas and Business Rules published on IRS.gov

must be followed rather than the formatting directions in

these instructions. For more information regarding

electronic filing, see Pubs. 5164 and 5165.

Substitute Returns Filed With the IRS

If you are filing your returns on paper, see Pub. 5223 for

specifications for private printing of substitute information

returns. You may not request special consideration. Only

forms that conform to the official form and the

specifications in Pub. 5223 are acceptable for filing with

the IRS. Substitute returns filed with the IRS must be

printed in landscape format.

Instructions for Forms 1094-C and 1095-C (2025)

VOID Box

Do not use this box on Form 1095-C.

Corrected Forms 1094-C and 1095-C

Tip: For information about filing corrections electronically,

see section 7.1 of Pub. 5165.

Corrected Returns

A corrected return should be filed as soon as possible

after an error is discovered. File the corrected returns as

follows.

Form 1094-C. If correcting information on the

Authoritative Transmittal (identified on Part I, line 19, as

the Authoritative Transmittal, one (and only one) of which

must be filed for each ALE Member reporting aggregate

employer-level data for all full-time employees and

employees of the ALE Member), file a standalone, fully

completed Form 1094-C, including the correct information,

and enter an “X” in the “CORRECTED” checkbox. Do not

file a return correcting information on a Form 1094-C that

is not the Authoritative Transmittal.

Caution: Do not file any other documents (for example,

Form 1095-C) with the corrected Authoritative Transmittal.

Form 1095-C. If correcting information on a Form

1095-C that was previously filed with the IRS, file a fully

completed Form 1095-C, including the correct information

and enter an “X” in the “CORRECTED” checkbox. File a

Form 1094-C (do not mark the “CORRECTED” checkbox

on Form 1094-C) with corrected Form(s) 1095-C. Furnish

the employee a copy of the corrected Form 1095-C,

unless the ALE Member was, and continues to be, eligible

for and used the alternative method of furnishing under

the Qualifying Offer Method for that employee for that

year’s furnishing. For more information, see Alternative

method of furnishing Form 1095-C to employees under

the Qualifying Offer Method.

Forms 1095-C filed with incorrect dollar amounts on

line 15, Employee Required Contribution, may fall under a

safe harbor for certain de minimis errors. The safe harbor

generally applies if no single amount in error differs from

the correct amount by more than $100. If the safe harbor

applies, you will not have to correct Form 1095-C to avoid

penalties. However, if the recipient elects for the safe

harbor not to apply, you may have to issue a corrected

Form 1095-C to avoid penalties. For more information, see

Notice 2017-9, 2017-4 I.R.B. 542, at IRS.gov/irb/2017-04

IRB/ar11.html.

Note: Enter an “X” in the “CORRECTED” checkbox only

when correcting a Form 1095-C previously filed with the

IRS. If you are correcting a Form 1095-C that was

previously furnished to a recipient, but not filed with the

IRS, write, type, or print “CORRECTED” on the new Form

1095-C furnished to the recipient.

Correcting information affecting statement furnished

to employee using an Alternative Furnishing Method

under the Qualifying Offer Method. If an ALE Member

eligible to use the Qualifying Offer Method had furnished

the employee an alternative statement, the ALE Member

must furnish the employee a corrected statement if it filed

5

a corrected Form 1095-C correcting the ALE Member’s

name, EIN, address, or contact name and telephone

number. If the ALE Member is no longer eligible to use an

alternative furnishing method for the employee for whom it

filed a corrected Form 1095-C, it must furnish a Form

1095-C to the employee and advise the employee that

Form 1095-C replaces the statement it had previously

furnished.

Caution: If you fail to file correct information returns or fail

to furnish a correct recipient statement, you may be

subject to a penalty. However, you are not required to file

corrected returns for missing or incorrect TINs if you meet

the reasonable cause criteria. For additional information,

see Pub. 1586, Reasonable Cause Regulations &

Requirements for Missing and Incorrect Name/TINs on

Information Returns.

Tip: See the charts for examples of errors and

step-by-step instructions for filing corrected returns.

Original Form 1095-C Submitted to IRS and Furnished to

Employee

IF any of the following are

incorrect ...

THEN ...

Name, SSN, ALE Member EIN

1. Prepare a new Form 1095-C.

Offer of Coverage (line 14)

2. Enter an “X” in the

“CORRECTED” checkbox at the

top of the form.

Employee Required Contribution 3. Submit corrected Forms 1095-C

with a non-authoritative Form

1094-C transmittal to the IRS.

Section 4980H Safe Harbor and

Other Relief Codes (line 16)

4. Furnish a corrected Form 1095-C

to the employee.

Covered Individuals Information

Original Authoritative Transmittal Form 1094-C

IF any of the following are

incorrect ...

THEN ...

ALE Member or Designated

Government Entity (Name

and/or EIN)

1. Prepare a new Authoritative

Transmittal, Form 1094-C.

Total number of Forms 1095-C

filed by and/or on behalf of ALE

Member

Aggregated ALE Group

Membership

Certifications of Eligibility

Minimum Essential Coverage

Offer Indicator

Section 4980H Full-Time

Employee Count for ALE

Member

Aggregated Group Indicator

Other ALE Members of

Aggregated ALE Group (Name

and/or EIN)

2. Enter an “X” in the

“CORRECTED” checkbox at the

top of the form.

3. Submit the standalone corrected

Form 1094-C with the correct

information present.

Original Alternative Furnishing Method Under the Qualifying

Offer Method Statement Furnished to Employee

IF any of the following are

incorrect ...

THEN ...

Name, SSN, ALE Member EIN

• Submission to the IRS:

1. Prepare a new Form 1095-C.

2. Enter an “X” in the

“CORRECTED” checkbox at the

top of the form.

3. Submit corrected Form

1095-Cs with a non-authoritative

Form 1094-C transmittal to the

IRS.

Offer of Coverage

• Furnish to employee:

If, after the correction, the ALE

Member is still eligible to use the

alternative furnishing method under

the Qualifying Offer Method, furnish

the employee either a Form 1095-C

or corrected statement.

If the ALE Member is no longer

eligible to use the alternative

furnishing method with respect to

the employee, furnish a Form

1095-C to the employee.

Furnishing Forms 1095-C to Employees

You will meet the requirement to furnish Form 1095-C to

an employee if the form is properly addressed and mailed

on or before the due date. If the due date falls on a

weekend or legal holiday, then the due date is the

following business day. A business day is any day that is

not a Saturday, Sunday, or legal holiday.

An ALE Member must furnish a Form 1095-C to each of

its full-time employees by March 2, 2026, for the 2025

calendar year. See Extensions of time to furnish

statements to recipients, below.

6

Instructions for Forms 1094-C and 1095-C (2025)

For more information on alternative furnishing methods

for employers, see Qualifying Offer Method, later.

Filers of Form 1095-C may truncate the social security

number (SSN) of an individual (the employee or any family

member of the employee receiving coverage) on Form

1095-C statements furnished to employees by showing

only the last four digits of the SSN and replacing the first

five digits with asterisks (*) or Xs. Truncation is not allowed

on forms filed with the IRS. In addition, an ALE Member’s

EIN may not be truncated on the statements furnished to

employees or the forms filed with the IRS.

Except as provided below, statements must be

furnished on paper by mail (or hand delivered), unless the

recipient affirmatively consents to receive the statement in

an electronic format. If mailed, the statement must be sent

to the employee’s last known permanent address, or if no

permanent address is known, to the employee’s

temporary address. For more information on furnishing

statements to non-full-time employees and nonemployees

who are enrolled in employer-sponsored self-insured

health coverage, see Alternative manner of furnishing

statements, later.

Consent to furnish statement electronically. An ALE

Member is required to obtain affirmative consent to furnish

a statement electronically. This requirement ensures that

statements are furnished electronically only to individuals

who are able to access them. The consent must relate

specifically to receiving the Form 1095-C electronically. An

individual may consent on paper or electronically, such as

by email. If consent is on paper, the individual must

confirm the consent electronically. A statement may be

furnished electronically by email or by informing the

individual how to access the statement on the ALE

Member’s website. Statements reporting coverage and

offers of coverage under an expatriate health plan,

however, may be furnished electronically unless the

recipient explicitly refuses to consent to receive the

statement in an electronic format. Specific information on

consents to furnish statements electronically can be found

in Regulations section 301.6056-2.

Extensions of time to furnish statements to recipients. The due date for furnishing Form 1095-C is

automatically extended from January 31, 2026, to March

2, 2026. Thus, no additional extensions will be granted.

Information reporting penalties. All employers subject

to the employer shared responsibility provisions and other

employers that sponsor self-insured group health plans

that fail to comply with the applicable information reporting

requirements may be subject to the general reporting

penalty provisions for failure to file correct information

returns and failure to furnish correct payee statements. For

returns required to be made and statements required to

be furnished for 2025 tax year returns, the following apply.

• The penalty for failure to file a correct information return

is $340 for each return for which the failure occurs, with

the total penalty for a calendar year not to exceed

$4,098,500.

• The penalty for failure to provide a correct payee

statement is $340 for each statement for which the failure

occurs, with the total penalty for a calendar year not to

exceed $4,098,500.

Instructions for Forms 1094-C and 1095-C (2025)

• Special rules apply that increase the per-statement and

total penalties if there is intentional disregard of the

requirement to file the returns and furnish the required

statements.

Penalties may be waived if the failure was due to

reasonable cause and not willful neglect. See section

6724 and Regulations section 301.6724-1 and

Regulations section 1.6055-1(h) (which relate to Form

1095-C, Part III). For additional information, see Pub.

1586.

Alternative manner of furnishing statements. If you

are an ALE Member that offers employer-sponsored,

self-insured health coverage and meets the requirements

of Regulations section 1.6055-1(g), you may use the

alternative manner of furnishing statements to

non-full-time employees and nonemployees who are

enrolled in the self-insured health coverage. To use the

alternative manner of furnishing statements, the following

conditions must be met.

• The employer must provide clear and conspicuous

notice, in a location on its website that is reasonably

accessible to all individuals, stating that individuals may

receive a copy of their statement upon request. The notice

must include an email address, a physical address to

which a request for a statement may be sent, and a

telephone number that individuals may use to contact the

employer with any questions. A notice posted on an

employer’s website must be written in plain, non-technical

terms and with letters of a font size large enough,

including any visual clues or graphical figures, to call to a

viewer’s attention that the information pertains to tax

statements reporting that individuals had health coverage.

For example, an employer’s website provides a clear and

conspicuous notice if it (1) includes a statement on the

main page, or a link on the main page, reading “Tax

Information,” to a secondary page that includes a

statement, in capital letters, “IMPORTANT HEALTH

COVERAGE TAX DOCUMENTS”; (2) explains how

non-full-time employees and nonemployees who are

enrolled in the plan may request a copy of Form 1095-C;

and (3) includes the employer’s email address, mailing

address, and telephone number.

• The employer must post the notice on its website by

March 2, 2026, and retain the notice in the same location

on its website through October 15, 2026.

• The employer must furnish the statement to a

requesting individual within 30 days of the date the

request is received. To satisfy this requirement, the

employer may furnish the statement electronically if the

recipient affirmatively consents.

Effective January 31, 2024, employers no longer have

to automatically send Form 1095-C to individuals.

Employers can now post a notice on its website informing

individuals that they may request a copy of the statement.

The requirement to provide the statement is met as long

as the notice satisfies the requirements set forth above

and is:

• Clear, conspicuous, and reasonably accessible to all

responsible individuals;

• Timely posted, which for tax year 2025 is by March 2,

2026, and retained until October 15 of the filing year; and

7

• Furnished to the individual no later than the later of

January 31, 2026, or 30 days after the date of the request.

For additional guidance, see IRS.gov irb/

2025-11_IRB#NOT-2025-15.

Specific Instructions for Form 1094-C

Part I—Applicable Large Employer Member

(ALE Member)

Line 1. Enter employer’s name. The employer is the ALE

Member.

Line 2. Enter the ALE Member’s EIN. Do not enter an

SSN. Enter the nine-digit EIN, including the dash.

Caution: If you are filing Form 1094-C, a valid EIN is

required at the time the form is filed. If a valid EIN is not

provided, Form 1094-C will not be processed. If you do

not have an EIN, you may apply for one online. Go to

IRS.gov/EIN. You may also apply by faxing or mailing

Form SS-4, Application for Employer Identification

Number, to the IRS. See the Instructions for Form SS-4

and Pub. 1635, Understanding Your EIN.

Lines 3–6. Enter the ALE Member’s complete address

(including room or suite no., if applicable). This address

should match the ALE Member’s address used on Form

1095-C.

Lines 7 and 8. Enter the name and telephone number of

the person to contact who is responsible for answering

any questions from the IRS regarding the filing of, or

information reported on, Form 1094-C or 1095-C. This

may be different than the contact information on line 10 of

Form 1095-C.

Note: If you are a Designated Governmental Entity (DGE)

filing on behalf of an ALE Member, complete lines 9–16. If

you are not a DGE filing on behalf of an ALE Member, do

not complete lines 9–16. Instead, skip to line 18. See

Designated Governmental Entity (DGE) in the Definitions

section of these instructions.

Line 9. If a DGE is filing on behalf of the ALE Member,

enter the name of the DGE.

Line 10. Enter the DGE’s EIN (including the dash). Do

not enter an SSN.

Caution: If you are a DGE that is filing Form 1094-C, a

valid EIN is required at the time the return is filed. If a valid

EIN is not provided, the return will not be processed. If the

DGE does not have an EIN when filing Form 1094-C, it

can get an EIN by applying online at IRS.gov/EIN or by

faxing or mailing a completed Form SS-4. See the

Instructions for Form SS-4 and Pub. 1635.

Lines 11–14. Enter the DGE’s complete address

(including room or suite no.).

Lines 15 and 16. Enter the name and telephone number

of the person to contact who is responsible for answering

any questions from the IRS regarding the filing of, or

information reported on, Form 1094-C.

Line 17. Reserved for future use.

8

Line 18. Enter the total number of Forms 1095-C

submitted with this Form 1094-C transmittal.

Line 19. If this Form 1094-C transmittal is the

Authoritative Transmittal that reports aggregate

employer-level data for the ALE Member, check the box

on line 19 and complete Parts II, III, and IV, to the extent

applicable. Otherwise, complete the signature portion of

Form 1094-C and leave the remainder of Parts II, III, and

IV blank.

There must be only one Authoritative Transmittal filed

for each ALE Member. If this is the only Form 1094-C

being filed for the ALE Member, this Form 1094-C must

report aggregate employer-level data for the ALE Member

and be identified on line 19 as the Authoritative

Transmittal. If multiple Forms 1094-C are being filed for an

ALE Member so that Forms 1095-C for all full-time

employees of the ALE Member are not attached to a

single Form 1094-C transmittal (because Forms 1095-C

for some full-time employees of the ALE Member are

being transmitted separately), one (and only one) of the

Forms 1094-C must report aggregate employer-level data

for the ALE Member and be identified on line 19 as the

Authoritative Transmittal. For more information, see

Authoritative Transmittal for ALE Members Filing Multiple

Forms 1094-C, earlier.

Part II—ALE Member Information

Reminder. Lines 20–22 should be completed only on the

Authoritative Transmittal for the ALE Member. For more

information, see Authoritative Transmittal for ALE

Members Filing Multiple Forms 1094-C, earlier.

Line 20. Enter the total number of Forms 1095-C that will

be filed by, and/or on behalf of, the ALE Member. This

includes all Forms 1095-C that are filed with this

transmittal, including those filed for individuals who

enrolled in the employer-sponsored, self-insured plan, if

any, and for any Forms 1095-C filed with a separate

transmittal filed by, or on behalf of, the ALE Member.

Line 21. If during any month of the calendar year the ALE

Member was a member of an Aggregated ALE Group,

check “Yes.” If you check “Yes,” also complete the

“Aggregated Group Indicator” in Part III, column (d), and

then complete Part IV to list the other members of the

Aggregated ALE Group. If, for all 12 months of the

calendar year, the employer was not a member of an

Aggregated ALE Group, check “No,” and do not complete

Part III, column (d), or Part IV.

Line 22. If the ALE Member meets the eligibility

requirements and is using one of the Offer Methods, it

must check the applicable box. See the descriptions of

Qualifying Offer Method and 98% Offer Method, later.

A. Qualifying Offer Method. Check this box if the ALE

Member is eligible to use, and is using, the Qualifying

Offer Method to report the information on Form 1095-C for

one or more full-time employees. Under the Qualifying

Offer Method, there is an alternative method of completing

Form 1095-C and an alternative method for furnishing

Form 1095-C to certain employees. If the ALE Member is

using either of these alternative rules, check this box. To

be eligible to use the Qualifying Offer Method, the ALE

Member must certify that it made a Qualifying Offer to one

Instructions for Forms 1094-C and 1095-C (2025)

or more of its full-time employees for all months during the

year in which the employee was a full-time employee for

whom an employer shared responsibility payment could

apply. Additional requirements described below must be

met to be eligible to use the alternative method for

furnishing Form 1095-C to employees under the

Qualifying Offer Method.

Alternative method of completing Form 1095-C

under the Qualifying Offer Method. If the ALE Member

reports using this method, it must not complete Form

1095-C, Part II, line 15, for any month for which a

Qualifying Offer is made. Instead, it must enter the

Qualifying Offer code 1A on Form 1095-C, line 14, for any

month for which the employee received a Qualifying Offer

(or in the “All 12 Months” box if the employee received a

Qualifying Offer for all 12 months), and must leave line 15

blank for any month for which code 1A is entered on

line 14. The ALE Member may, but is not required to, enter

an applicable code on line 16 for any month for which

code 1A is entered on line 14; a Qualifying Offer is, by

definition, treated as an offer that falls within an

affordability safe harbor even if no code is entered on

line 16.

An ALE Member is not required to use the Qualifying

Offer Method even if it is eligible, and instead may enter

on line 14 the applicable offer code and then enter on

line 15 the Employee Required Contribution.

Tip: If the ALE Member is eligible to use the Qualifying

Offer Method, it may report on Form 1095-C by entering

the Qualifying Offer code 1A on Form 1095-C, line 14, for

any month for which it made a Qualifying Offer to an

employee, even if the employee did not receive a

Qualifying Offer for all 12 calendar months. However, if an

employee receives a Qualifying Offer for less than all 12

months, the ALE Member must furnish a copy of Form

1095-C to the employee (rather than using the alternative

method of furnishing Form 1095-C described later).

Example. Employee’s employment with Employer

begins on January 1. Employee is in a health coverage

waiting period (and an employer shared responsibility

payment could not apply with respect to Employee,

because Employee is in a Limited Non-Assessment

Period) until April 1 and is a full-time employee for the

remainder of the calendar year. Employer makes a

Qualifying Offer to Employee for coverage beginning on

April 1 and for the remainder of the calendar year.

Employer is eligible to use the Qualifying Offer method

because it has made a Qualifying Offer to at least one

full-time employee for all months in which both (1) the

employee was a full-time employee, and (2) an employer

shared responsibility payment could apply with respect to

the employee. Employer may use the alternative method

of completing Form 1095-C under the Qualifying Offer

Method for this Employee. However, Employer may not

use the alternative method of furnishing Form 1095-C to

Employee under the Qualifying Offer Method because

Employee did not receive a Qualifying Offer for all 12

months of the calendar year.

Alternative method of furnishing Form 1095-C to

employees under the Qualifying Offer Method. An

ALE Member that is eligible to use the Qualifying Offer

Method may use the alternative method of furnishing Form

Instructions for Forms 1094-C and 1095-C (2025)

1095-C only for a full-time employee who (1) received a

Qualifying Offer for all 12 months of the calendar year, and

(2) did not enroll in employer-sponsored, self-insured

coverage. For such an employee, an ALE Member meets

its obligation to furnish a Form 1095-C to the employee if it

furnishes the employee a statement containing the

following information.

• Employer/ALE Member name, address, and EIN.

• Contact name and telephone number at which the

employee may receive information about the offer of

coverage and the information on the Form 1095-C filed

with the IRS for that employee.

• Notification that, for all 12 months of the calendar year,

the employee and their spouse and dependents, if any,

received a Qualifying Offer and therefore the employee is

not eligible for a premium tax credit.

• Information directing the employee to see Pub. 974,

Premium Tax Credit (PTC), for more information on

eligibility for the premium tax credit.

An ALE Member is not required to use the alternative

method of furnishing for an employee even if the

alternative method would be allowed. Instead, the ALE

Member may furnish a copy of Form 1095-C as filed with

the IRS (with or without the statement described earlier).

As stated earlier, an ALE Member may not use the

alternative furnishing method for a full-time employee who

enrolled in self-insured coverage. Rather, the ALE

Member must furnish Form 1095-C, including the

information reporting enrollment in the coverage on Form

1095-C, Part III.

B. Reserved for future use.

C. Reserved for future use.

D. 98% Offer Method. Check this box if the employer

is eligible for, and is using, the 98% Offer Method. To be

eligible to use the 98% Offer Method, an employer must

certify that, taking into account all months during which

the individuals were employees of the ALE Member and

were not in a Limited Non-Assessment Period, the ALE

Member offered affordable health coverage providing

minimum value to at least 98% of its employees for whom

it is filing a Form 1095-C employee statement, and offered

minimum essential coverage to those employees’

dependents. The ALE Member is not required to identify

which of the employees for whom it is filing were full-time

employees, but the ALE Member is still required, under

the general reporting rules, to file Forms 1095-C on behalf

of all its full-time employees who were full-time employees

for 1 or more months of the calendar year. To ensure

compliance with the general reporting rules, an ALE

Member should confirm for any employee for whom it fails

to file a Form 1095-C that the employee was not a full-time

employee for any month of the calendar year. For this

purpose, the health coverage is affordable if the ALE

Member meets one of the section 4980H affordability safe

harbors.

Example. Employer has 325 employees. Of those 325

employees, Employer identifies 25 employees as not

possibly being full-time employees because they are

scheduled to work 10 hours per week and are not eligible

for additional hours. Of the remaining 300 employees, 295

are offered affordable minimum value coverage for all

periods during which they are employed other than any

9

applicable waiting period (which qualifies as a Limited

Non-Assessment Period). Employer files a Form 1095-C

for each of the 300 employees (excluding the 25

employees that it identified as not possibly being full-time

employees). Employer may use the 98% Offer Method

because it makes an affordable offer of coverage that

provides minimum value to at least 98% of the employees

for whom Employer files a Form 1095-C. Using this

method, Employer does not identify whether each of the

300 employees is a full-time employee. However,

Employer must still file a Form 1095-C for all of its full-time

employees. Employer chooses to file a Form 1095-C on

behalf of all 300 employees, including the five employees

to whom it did not offer coverage, because if one or more

of those employees was, in fact, a full-time employee for 1

or more months of the calendar year, Employer would be

required to have filed a Form 1095-C on behalf of those

employees.

Note: If an ALE Member uses the 98% Offer Method, it is

not required to complete the “Section 4980H Full-Time

Employee Count for ALE Member” in Part III, column (b).

Part III—ALE Member Information—Monthly

(Lines 23–35)

Column (a)—Minimum Essential Coverage Offer Indicator.

• If the ALE Member offered minimum essential

coverage, including an individual coverage HRA, to at

least 95% of its full-time employees and their dependents

for the entire calendar year, enter “X” in the “Yes”

checkbox on line 23 for “All 12 Months” or for each of the

12 calendar months.

• If the ALE Member offered minimum essential

coverage, including an individual coverage HRA, to at

least 95% of its full-time employees and their dependents

only for certain calendar months, enter “X” in the “Yes”

checkbox for each applicable month.

• For the months, if any, for which the ALE Member did

not offer minimum essential coverage, including an

individual coverage HRA, to at least 95% of its full-time

employees and their dependents, enter “X” in the “No”

checkbox for each applicable month.

• If the ALE Member did not offer minimum essential

coverage, including an individual coverage HRA, to at

least 95% of its full-time employees and their dependents

for any of the 12 months, enter “X” in the “No” checkbox

for “All 12 Months” or for each of the 12 calendar months.

Note: For purposes of column (a), an employee in a

Limited Non-Assessment Period is not counted in

determining whether minimum essential coverage was

offered to at least 95% of an ALE Member’s full-time

employees and their dependents. For a description of the

differences between the definition of the term “Limited

Non-Assessment Period” used with respect to section

4980H(a) and the definition used with respect to section

4980H(b), relating to whether the ALE Member offers

minimum value coverage at the end of the Limited

Non-Assessment Period, see the Definitions section.

Tip: An employee who is treated as having been offered

health coverage, including an individual coverage HRA,

10

for purposes of section 4980H (even though not actually

offered) is treated as offered minimum essential coverage

for this purpose. For example, for the months for which the

ALE Member is eligible for multiemployer arrangement

interim guidance (if the ALE Member is contributing on

behalf of an employee whether or not the employee is

eligible for coverage under the multiemployer plan) with

respect to an employee, that employee should be treated

as having been offered minimum essential coverage for

purposes of column (a). For different rules for purposes of

reporting offers of coverage on Form 1095-C, see the

specific instructions for Form 1095-C, Part II, Line 14.

Tip: For purposes of column (a), if the ALE Member

offered minimum essential coverage to all but five of its

full-time employees and their dependents, and five is

greater than 5% of the number of full-time employees of

the ALE Member, the ALE Member may report in column

(a) as if it offered health coverage to at least 95% of its

full-time employees and their dependents (even if it

offered health coverage to less than 95% of its full-time

employees and their dependents, for example, to 75 of its

80 full-time employees and their dependents).

See Definitions, later, for more information on an offer

of health coverage.

Column (b)—Section 4980H Full-Time Employee

Count for ALE Member. Enter the number of full-time

employees for each month, but do not count any

employee in a Limited Non-Assessment Period. If the

number of full-time employees (excluding employees in a

Limited Non-Assessment Period) for a month is zero,

enter -0-. An employee should be counted as a full-time

employee for a month if the employee satisfied the

definition of “full-time employee” under the monthly

measurement method or the look-back measurement

method (as applicable) on any day of the month. See

Full-time employee and Limited Non-Assessment Period

in the Definitions section. Be sure to use the section

4980H definition and not any other definition of the term

“full-time employee” that you may use for other purposes.

Example. Employer uses the look-back measurement

method to determine the full-time status of its employees.

Employee, who is not in a Limited Non-Assessment

Period, averaged over 130 hours of service per month

during the measurement period that corresponds with the

stability period starting January 1, 2025, and ending

December 31, 2025. Employee terminates employment

with Employer on February 15, 2025. Employer must

include Employee in the number of full-time employees

reported in column (b) for January and February. See the

description of code 2B in the instructions for line 16 of

Form 1095-C, later, for rules for reporting an offer of

coverage in an employee’s final month of employment.

Note: If the ALE Member certified that it was eligible for

the 98% Offer Method by selecting box D, on line 22, it is

not required to complete column (b).

Column (c)—Total Employee Count for ALE Member.

Enter the total number of all of the ALE Member’s

employees, including full-time employees and

non-full-time employees, and employees in a Limited

Non-Assessment Period, for each calendar month. An

Instructions for Forms 1094-C and 1095-C (2025)

ALE Member must choose to use one of the following

days of the month to determine the number of employees

per month and must use that day for all months of the

year: (1) the 1st day of each month, (2) the last day of

each month, (3) the 12th day of each month, (4) the 1st

day of the 1st payroll period that starts during each month,

or (5) the last day of the 1st payroll period that starts

during each month (provided that for each month that last

day falls within the calendar month in which the payroll

period starts). If the total number of employees was the

same for every month of the entire calendar year, enter

that number in line 23, column (c), “All 12 Months,” or in

the boxes for each month of the calendar year. If the

number of employees for any month is zero, enter -0-.

Column (d)—Aggregated Group Indicator. An ALE

Member must complete this column if it checked “Yes” on

line 21, indicating that, during any month of the calendar

year, it was a member of an Aggregated ALE Group. If the

ALE Member was a member of an Aggregated ALE Group

during each month of the calendar year, enter “X” in the

“All 12 Months” box or in the boxes for each of the 12

calendar months. If the ALE Member was not a member of

an Aggregated ALE Group for all 12 months but was a

member of an Aggregated ALE Group for 1 or more

month(s), enter “X” in each month for which it was a

member of an Aggregated ALE Group. If an ALE Member

enters “X” in 1 or more months in this column, it must also

complete Part IV.

Part IV—Other ALE Members of Aggregated ALE

Group (Lines 36–65)

An ALE Member must complete this section if it checks

“Yes” on line 21. If the ALE Member was a member of an

Aggregated ALE Group (with other ALE Members) for any

month of the calendar year, enter the name(s) and EIN(s)

of up to 30 of the other Aggregated ALE Group members

(not including the reporting ALE Member). If there are

more than 30 members of the Aggregated ALE Group (not

including the reporting ALE Member), enter the 30 with

the highest monthly average number of full-time

employees (using the number reported in Part III, column

(b), if a number was required to be reported) for the year

or for the number of months during which the ALE

Member was a member of the Aggregated ALE Group. If

any member of the Aggregated ALE Group uses the 98%

Offer Method and thus is not required to identify which

employees are full-time employees, all ALE Members of

the Aggregated ALE Group should use the monthly

average number of total employees rather than the

monthly average number of full-time employees for this

purpose. Regardless of the number of members in the

Aggregated ALE Group, list only the 30 members in

descending order, listing first the member with the highest

average monthly number of full-time employees (or

highest average number of total employees, if any

member of the Aggregated ALE Group uses the 98%

Offer Method), but do not include the reporting ALE

Member. The reporting ALE Member must also complete

Part III, column (d), to indicate which months it was part of

an Aggregated ALE Group.

Caution: If you are filing Form 1094-C, a valid EIN is

required at the time it is filed. If a valid EIN is not provided,

Instructions for Forms 1094-C and 1095-C (2025)

Form 1094-C will not be processed. If you do not have an

EIN, you may apply for one online. Go to IRS.gov/EIN. You

may also apply by faxing or mailing Form SS-4 to the IRS.

See the Instructions for Form SS-4 and Pub. 1635.

Specific Instructions for Form 1095-C

Part I—Employee

Line 1. Enter the name of the employee (first name,

middle initial, last name).

Line 2. Enter the nine-digit SSN of the employee

(including the dashes).

Lines 3–6. Enter the employee’s complete address,

including apartment no., if applicable. A country code is

not required for U.S. addresses.

Part I—Applicable Large Employer Member

(Employer)

Line 7. Enter the name of the ALE Member.

Line 8. Enter the ALE Member’s EIN. Do not enter an

SSN. Enter the nine-digit EIN, including the dash. The

ALE Member’s name and EIN should match the name and

EIN of the ALE Member reported on lines 1 and 2 of Form

1094-C.

Caution: If you are filing Form 1095-C, a valid EIN is

required at the time it is filed. If a valid EIN is not provided,

Form 1095-C will not be processed. If you do not have an

EIN, you may apply for one online. Go to IRS.gov/EIN. You

may also apply by faxing or mailing Form SS-4 to the IRS.

See the Instructions for Form SS-4 and Pub. 1635.

Lines 9 and 11–13. Enter the ALE Member’s complete

address (including room or suite no., if applicable). This

address should match the address reported on lines 3–6

of the Form 1094-C.

Line 10. Enter the telephone number of the person to

contact whom the recipient may call about the information

reported on the form. This may be different than the

contact information entered on line 8 of Form 1094-C.

Part II—Employee Offer of Coverage

Age. If the employee was offered an individual coverage

HRA, enter the employee’s age on January 1, 2025. Note

that for non-calendar year plans or for employees who

become eligible during the plan year, this age may not be

the Applicable age used to determine Employee Required

Contribution.

Plan Start Month. This box is required for the 2025 Form

1095-C and the ALE Member may not leave it blank. To

complete the box, enter the two-digit number (01 through

12) indicating the calendar month during which the plan

year begins of the health plan in which the employee is

offered coverage (or would be offered coverage if the

employee were eligible to participate in the plan). If more

than 1 plan year could apply (for instance, if the ALE

Member changes the plan year during the year), enter the

earliest applicable month. If there is no health plan under

which coverage is offered to the employee, enter “00.”

11

Line 14. For each calendar month, enter the applicable

code from Code Series 1. If the same code applies for all

12 calendar months, you may enter the applicable code in

the “All 12 Months” box and not complete the individual

calendar month boxes, or you may enter the code in each

of the boxes for the 12 calendar months. If an employee

was not offered coverage for a month, enter code 1H. Do

not leave line 14 blank for any month (including months

when the individual was not an employee of the ALE

Member). An ALE Member offers health coverage for a

month only if it offers health coverage that would provide

coverage for every day of that calendar month. Thus, if

coverage terminates before the last day of the month

(because, for instance, the employee terminates

employment with the ALE Member, or otherwise loses

eligibility for coverage under the plan), the employee does

not actually have an offer of coverage for that month (and

code 1H should therefore be entered on line 14). See

line 16, code 2B, later, for how the ALE Member may

complete line 16 in the event that coverage terminates

before the last day of the month.

A code must be entered for each calendar month,

January through December, even if the employee was not

a full-time employee for 1 or more of the calendar months.

Enter the code identifying the type of health coverage

actually offered by the ALE Member (or on behalf of the

ALE Member) to the employee, if any. If the employee was

not actually offered coverage, enter code 1H (no offer of

coverage) on line 14.

For reporting offers of coverage for 2025, an ALE

Member relying on the multiemployer arrangement interim

guidance should enter code 1H on line 14 for any month

for which the ALE Member enters code 2E on line 16

(indicating that the ALE Member was required to

contribute to a multiemployer plan on behalf of the

employee for that month and therefore is eligible for

multiemployer interim rule relief). For a description of the

multiemployer arrangement interim guidance, see Offer of

health coverage in the Definitions section. For reporting

for 2025, code 1H may be entered without regard to

whether the employee was eligible to enroll, or enrolled in,

coverage under the multiemployer plan. For reporting for

2026 and future years, ALE Members relying on the

multiemployer arrangement interim guidance may be

required to report offers of coverage made through a

multiemployer plan in a different manner.

Indicator Codes for Employee Offer of Coverage

(Form 1095-C, Line 14)

Code Series 1—Offer of Coverage. The Code Series 1

indicator codes specify the type of coverage, if any,

offered to an employee, the employee’s spouse, and the

employee’s dependents. The term Dependent has the

specific meaning set forth in the Definitions section of

these instructions. In addition, for this purpose, an offer of

coverage is treated as made to an employee’s

dependents only if the offer of coverage is made to an

unlimited number of dependents regardless of the actual

number of dependents, if any, an employee has during

any particular calendar month.

12

If the type of coverage, if any, offered to an employee

was the same for all 12 months in the calendar year, enter

the Code Series 1 indicator code corresponding to the

type of coverage offered either in the “All 12 Months” box

or in each of the 12 boxes for the calendar months.

Conditional offer of spousal coverage. Codes 1J

and 1K address conditional offers of spousal coverage

(also referred to as “coverage offered conditionally”). A

conditional offer is an offer of coverage that is subject to

one or more reasonable, objective conditions (for

example, an offer to cover an employee’s spouse only if

the spouse is not eligible for coverage under Medicare or

a group health plan sponsored by another employer).

Using codes 1J and 1K, an ALE Member may report a

conditional offer to a spouse as an offer of coverage,

regardless of whether the spouse meets the reasonable,

objective condition. A conditional offer may impact a

spouse’s eligibility for the premium tax credit under

section 36B only if all conditions to the offer are satisfied

(that is, the spouse was actually offered the coverage and

eligible for it) and the Exchange makes a determination

about the affordability of the offer. To help employees (and

spouses) who have received a conditional offer determine

their eligibility for the premium tax credit, the ALE Member

should be prepared to provide, upon request, a list of any

and all conditions applicable to the spousal offer of

coverage. As is noted in the definition of Dependent in the

Definitions section, a spouse is not a dependent for

purposes of section 4980H.

An ALE Member may not report a conditional offer of

coverage to an employee’s dependents as an offer to the

dependents, unless the ALE Member knows that the

dependents met the condition to be eligible for the ALE

Member’s coverage. Further, an offer of coverage is

treated as made to an employee’s dependents only if the

offer of coverage is made to an unlimited number of

dependents regardless of the actual number of

dependents, if any, an employee has during any particular

calendar month.

COBRA continuation coverage. An offer of COBRA

continuation coverage is reported differently depending on

whether or not the offer is made due to an employee’s

termination of employment.

An offer of COBRA continuation coverage that is made

to a former employee (or to a former employee’s spouse

or dependents) due to termination of employment should

not be reported as an offer of coverage on line 14. In this

situation, code 1H (no offer of coverage) must be entered

on line 14 for any month for which the offer of COBRA

continuation coverage applies, and code 2A (Employee

not employed during the month) must be entered on

line 16 (see the instructions for line 16), without regard to

whether the employee or spouse or dependents enrolled

in the COBRA coverage. However, for the month in which

the employee terminates employment with the ALE

Member, see the instructions for line 16, code 2B.

An offer of COBRA continuation coverage that is made

to an employee who remains employed by the ALE

Member (or to that employee’s spouse and dependents)

should be reported on line 14 as an offer of coverage, but

only for any individual who receives an offer of COBRA

continuation coverage (or an offer of similar coverage that

Instructions for Forms 1094-C and 1095-C (2025)

is made at the same time as the offer of COBRA

continuation coverage is made to enrolled individuals).

Generally, an offer of COBRA continuation coverage is

required to be made only to individuals who were enrolled

in coverage and would lose eligibility for coverage due to

the COBRA qualifying event, but an ALE Member may

choose to extend a similar offer of coverage to a spouse

or dependent even if the offer is not required by COBRA.

Example. During the applicable open enrollment

period for its health plan, Employer makes an offer of

minimum essential coverage providing minimum value to

Employee and to Employee’s spouse and dependents.

Employee elects to enroll in employee-only coverage

starting January 1. On June 1, Employee experiences a

reduction in hours that results in loss of eligibility for

coverage under the plan. As of June 1, Employer

terminates Employee’s existing coverage and makes an

offer of COBRA continuation coverage to Employee, but

does not make an offer to Employee’s spouse and

dependents. Employer should enter code 1E (Minimum

essential coverage providing minimum value offered to

employee and at least minimum essential coverage

offered to dependent(s) and spouse) on line 14 for months

January–May, and should enter code 1B (Minimum

essential coverage providing minimum value offered to

employee only) on line 14 for months June–December.

Note: Notwithstanding the preceding instructions for

completing line 14 of Form 1095-C, for purposes of

section 4980H, an ALE Member is treated as having

made an offer to the employee’s dependents for an entire

plan year if the ALE Member provided the employee an

effective opportunity to enroll the employee’s dependents

at least once for the plan year, even if the employee

declined to enroll the dependents in the coverage and, as

a result, the dependents later did not receive an offer of

COBRA coverage.

Post-employment (non-COBRA) coverage. An offer

of post-employment coverage to a former employee (or to

that former employee’s spouse or dependent(s)) for

coverage that would be effective after the employee has

terminated employment (such as at retirement) should not

be reported as an offer of coverage on line 14. If the ALE

Member is otherwise required to file Form 1095-C for the

former employee (because, for example, the individual

was a full-time employee for 1 or more months in the

calendar year in which the termination of employment

occurred), the ALE Member should enter code 1H (no

offer of coverage) on line 14 for any month to which an

offer of post-employment coverage applies, and should

also enter code 2A (not an employee) on line 16 (see the

instructions for line 16).

Tip: For additional information, including examples about

reporting offers of COBRA continuation coverage and

post-employment coverage, go to IRS.gov/AffordableCare-Act/Employers/Questions-and-Answers-aboutInformation-Reporting-by-Employers-on-Form-1094-Cand-Form-1095-C.

• 1A. Qualifying Offer: Minimum essential coverage

providing minimum value offered to full-time employee

with Employee Required Contribution equal to or less than

9.5% (as adjusted) of mainland single federal poverty line

Instructions for Forms 1094-C and 1095-C (2025)

and at least minimum essential coverage offered to

spouse and dependent(s).

Tip: This code may be used to report for specific months

for which a Qualifying Offer was made, even if the

employee did not receive a Qualifying Offer for all 12

months of the calendar year. However, an ALE Member

may not use the Alternative Furnishing Method for an

employee who did not receive a Qualifying Offer for all 12

calendar months.

• 1B. Minimum essential coverage providing minimum

value offered to employee only.

• 1C. Minimum essential coverage providing minimum

value offered to employee and at least minimum essential

coverage offered to dependent(s) (not spouse).

• 1D. Minimum essential coverage providing minimum

value offered to employee and at least minimum essential

coverage offered to spouse (not dependent(s)). Do not

use code 1D if the coverage for the spouse was offered

conditionally. Instead, use code 1J.

• 1E. Minimum essential coverage providing minimum

value offered to employee and at least minimum essential

coverage offered to dependent(s) and spouse. Do not use

code 1E if the coverage for the spouse was offered

conditionally. Instead, use code 1K.

• 1F. Minimum essential coverage NOT providing

minimum value offered to employee; employee and

spouse or dependent(s); or employee, spouse, and

dependents.

• 1G. Offer of coverage for at least 1 month of the

calendar year to an individual who was not an employee

for any month of the calendar year or to an employee who

was not a full-time employee for any month of the calendar

year (which may include 1 or more months in which the

individual was not an employee) and who enrolled in

self-insured coverage for 1 or more months of the

calendar year.

Note: Code 1G applies for the entire year or not at all.

Therefore, if code 1G applies, an ALE Member must enter

code 1G on line 14 in the “All 12 Months” column or in

each separate monthly box (for all 12 months).

• 1H. No offer of coverage (employee not offered any

health coverage or employee offered coverage that is not

minimum essential coverage, which may include 1 or

more months in which the individual was not an

employee).

• 1I. Reserved for future use.

• 1J. Minimum essential coverage providing minimum

value offered to employee and at least minimum essential

coverage conditionally offered to spouse; minimum

essential coverage not offered to dependent(s). (See

Conditional offer of spousal coverage, earlier, for an

additional description of conditional offers.)

• 1K. Minimum essential coverage providing minimum

value offered to employee; at least minimum essential

coverage offered to dependents; and at least minimum

essential coverage conditionally offered to spouse. (See

Conditional offer of spousal coverage, earlier, for an

additional description of conditional offers.)

• 1L. Individual coverage HRA offered to employee only

with affordability determined by using employee’s primary

residence location ZIP code.

13

• 1M. Individual coverage HRA offered to employee and

dependent(s) (not spouse) with affordability determined

by using employee’s primary residence location ZIP code.

• 1N. Individual coverage HRA offered to employee,

spouse, and dependent(s) with affordability determined by

using employee’s primary residence location ZIP code.

• 1O. Individual coverage HRA offered to employees only

using the employee’s primary employment site ZIP code

affordability safe harbor.

• 1P. Individual coverage HRA offered to employee and

dependent(s) (not spouse) using the employee’s primary

employment site ZIP code affordability safe harbor.

• 1Q. Individual coverage HRA offered to employee,

spouse, and dependent(s) using employee’s primary

employment site ZIP code affordability safe harbor.

• 1R. Individual coverage HRA that is NOT affordable

offered to employee; employee and spouse, or

dependent(s); or employee, spouse, and dependents.

• 1S. Individual coverage HRA offered to an individual

who was not a full-time employee.

• 1T. Individual coverage HRA offered to employee and

spouse (not dependents) with affordability determined

using employee’s primary residence location ZIP code.

• 1U. Individual coverage HRA offered to employee and

spouse (not dependents) using employee’s primary

employment site ZIP code affordability safe harbor.

• 1V. Reserved for future use.

• 1W. Reserved for future use.

• 1X. Reserved for future use.

• 1Y. Reserved for future use.

• 1Z. Reserved for future use.

Line 15. Complete line 15 only if code 1B, 1C, 1D, 1E, 1J,

1K, 1L, 1M, 1N, 1O, 1P, 1Q, 1T, or 1U is entered on line 14

either in the “All 12 Months” box or in any of the monthly

boxes. Enter the amount of the Employee Required

Contribution, which is, generally, the employee share of

the monthly cost for the lowest-cost, self-only, minimum

essential coverage providing minimum value that is

offered to the employee. For additional details on how to

determine the Employee Required Contribution, including

how to determine the Employee Required Contribution for

the individual coverage HRA, see the Definitions section,

later. Enter the amount, including any cents. If the

employee is offered coverage but the Employee Required

Contribution is zero, enter “0.00” (do not leave blank). If

the Employee Required Contribution was the same

amount for all 12 calendar months, you may enter that

monthly amount in the “All 12 Months” box and not

complete the monthly boxes. If the Employee Required

Contribution was not the same for all 12 months (for

instance, if an ALE Member has a non-calendar year plan

and the employee share of the premium changes with the

new plan year that starts in 2025), enter the amount in

each calendar month for which the employee was offered

minimum value coverage. See the definition of Employee

Required Contribution in the Definitions section, for more

information, including on how to determine the monthly

required contribution from annual data.

Tip: For line 15, the amount entered might not be the

amount the employee is paying for the coverage, for

example, if the employee chose to enroll in more

expensive coverage, such as family coverage, or if the

14

employee is eligible for certain other healthcare

arrangements.

Line 16. For each calendar month, enter the applicable

code, if any, from Code Series 2. Enter only one code from

Code Series 2 per calendar month. The instructions below

address which code to use for a month if more than one

code from Code Series 2 could apply. If the same code

applies for all 12 calendar months, you may enter the code

in the “All 12 Months” box and not complete the monthly

boxes. If none of the codes apply for a calendar month,

leave the line blank for that month.

Code Series 2—Section 4980H Safe Harbor Codes

and Other Relief for ALE Members. An ALE Member

enters the applicable Code Series 2 indicator code, if any,

on line 16 to report for 1 or more months of the calendar

year that one of the following situations applied to the

employee.

• The employee was not employed or was not a full-time

employee,

• The employee enrolled in the minimum essential

coverage offered,

• The employee was in a Limited Non-Assessment

Period with respect to section 4980H(b),

• The ALE Member met one of the section 4980H

affordability safe harbors with respect to this employee, or

• The ALE Member was eligible for multiemployer interim

rule relief for this employee.

If no indicator code applies, leave line 16 blank. In some

circumstances, more than one indicator code could apply

to the same employee in the same month. For example,

an employee could be enrolled in health coverage for a

particular month during which they are not a full-time

employee. However, only one code may be used for a

particular calendar month. For any month in which an

employee enrolled in minimum essential coverage, in

general, indicator code 2C reporting enrollment is used

instead of any other indicator code that could also apply

(but see the exceptions to this rule below regarding the

multiemployer interim rule relief and enrollment in COBRA

continuation coverage or other post-employment

coverage). For an employee who did not enroll in health

coverage, there are some specific ordering rules for which

code to use. See the descriptions of the codes.

Note: There is no code to enter on line 16 to indicate that

a full-time employee offered coverage either did not enroll

in the coverage or waived the coverage.

• 2A. Employee not employed during the month. Enter

code 2A if the employee was not employed on any day of

the calendar month. Do not use code 2A for a month if the

individual was an employee of the ALE Member on any

day of the calendar month. Do not use code 2A for the

month during which an employee terminates employment

with the ALE Member.

• 2B. Employee not a full-time employee. Enter code 2B if

the employee is not a full-time employee for the month

and did not enroll in minimum essential coverage, if

offered for the month. Enter code 2B also if the employee

is a full-time employee for the month and whose offer of

coverage (or coverage if the employee was enrolled)

ended before the last day of the month solely because the

employee terminated employment during the month (so

Instructions for Forms 1094-C and 1095-C (2025)

that the offer of coverage or coverage would have

continued if the employee had not terminated employment

during the month).

• 2C. Employee enrolled in health coverage offered.

Enter code 2C for any month in which the employee

enrolled for each day of the month in health coverage

offered by the ALE Member, regardless of whether any

other code in Code Series 2 might also apply (for

example, the code for a section 4980H affordability safe

harbor) except as provided below. Do not enter code 2C

on line 16 for any month in which the multiemployer

interim rule relief applies (enter code 2E). Do not enter

code 2C on line 16 if code 1G is entered on line 14. Do not

enter code 2C on line 16 for any month in which a

terminated employee is enrolled in COBRA continuation

coverage or other post-employment coverage (enter code

2A). Do not enter code 2C on line 16 for any month in

which the employee enrolled in coverage that was not

minimum essential coverage.

• 2D. Employee in a section 4980H(b) Limited

Non-Assessment Period. Enter code 2D for any month

during which an employee is in a section 4980H(b)

Limited Non-Assessment Period. If an employee is in an

initial measurement period, enter code 2D (employee in a

section 4980H(b) Limited Non-Assessment Period) for the

month, and not code 2B (employee not a full-time

employee). For an employee in a section 4980H(b)

Limited Non-Assessment Period for whom the ALE

Member is also eligible for the multiemployer interim rule

relief for the month, enter code 2E (multiemployer interim

rule relief) and not code 2D (employee in a section

4980H(b) Limited Non-Assessment Period).

• 2E. Multiemployer interim rule relief. Enter code 2E for

any month for which the multiemployer arrangement

interim guidance applies for that employee, regardless of

whether any other code in Code Series 2 (including code

2C) might also apply. This relief is described under Offer

of Health Coverage in the Definitions section of these

instructions.

Note: Although ALE Members may use the section

4980H affordability safe harbors to determine affordability

for purposes of the multiemployer arrangement interim

guidance, an ALE Member eligible for the relief provided

in the multiemployer arrangement interim guidance for a

month for an employee should enter code 2E

(multiemployer interim rule relief), and not code 2F, 2G, or

2H (codes for section 4980H affordability safe harbors).

• 2F. Section 4980H affordability Form W-2 safe harbor.

Enter code 2F if the ALE Member used the section 4980H

Form W-2 safe harbor to determine affordability for

purposes of section 4980H(b) for this employee for the

year. If an ALE Member uses this safe harbor for an

employee, it must be used for all months of the calendar

year for which the employee is offered health coverage.

• 2G. Section 4980H affordability federal poverty line safe

harbor. Enter code 2G if the ALE Member used the

section 4980H federal poverty line safe harbor to

determine affordability for purposes of section 4980H(b)

for this employee for any month(s).

• 2H. Section 4980H affordability rate of pay safe harbor.

Enter code 2H if the ALE Member used the section 4980H

rate of pay safe harbor to determine affordability for

Instructions for Forms 1094-C and 1095-C (2025)

purposes of section 4980H(b) for this employee for any

month(s).

Note: An affordability safe harbor code should not be

entered on line 16 for any month that the ALE Member did

not offer minimum essential coverage, including an

individual coverage HRA, to at least 95% of its full-time

employees and their dependents (that is, any month for

which the ALE Member checked the “No” box on Form

1094-C, Part III, column (a)). For more information, see the

instructions for Form 1094-C, Part III, column (a).

• 2I. Reserved for future use.

Note: References to 9.5% in the section 4980H

affordability safe harbors and Qualifying Offer Method are

applied based on the percentage as indexed for purposes

of applying the affordability thresholds under section 36B

(the premium tax credit). The percentage, as adjusted, is

8.39% for plan years beginning in 2024, and 9.02% for

plan years beginning in 2025.

Line 17. If the ALE Member used code 1L, 1M, 1N, 1O,

1P, 1Q, 1T, or 1U because it offered the employee an

individual coverage HRA, enter the appropriate ZIP code

used for identifying the lowest cost silver plan used to

calculate the Employee Required Contribution in line 15.

This will be the ZIP code of the employee’s residence

(code 1L, 1M, 1N, or 1T) or the ZIP code of the

employee’s primary site of employment if the ALE Member

uses the work location safe harbor (code 1O, 1P, 1Q, or

1U).

Location safe harbor for individual coverage HRAs.

For purposes of section 4980H(b), an employer may use

the cost of self-only coverage for the lowest cost silver

plan for the employee for self-only coverage offered

through the Exchange where the employee’s primary site

of employment is located for determining whether an offer

of an individual coverage HRA to a full-time employee is

affordable. The ZIP code for the employee’s primary site

of employment is used to identify the applicable lowest

cost silver plan to determine affordability.

Note: In addition to the location safe harbor for individual

coverage HRAs, ALE Members may use the section

4980H affordability safe harbors to determine affordability

for purposes of section 4980H(b) for an employee for the

year.

Part III—Covered Individuals (Lines 18–30)

Note: If there are more than 13 covered individuals,

additional copies of page 3, Part III, may be used.

Complete Part III ONLY if the ALE Member offers

employer-sponsored, self-insured health coverage,

including an individual coverage HRA, in which the

employee or other individual enrolled. For this purpose,

employer-sponsored, self-insured health coverage does

not include coverage under a multiemployer plan. Do not

complete Part III if the ALE Member offers coverage only

under an insured group health plan. If an ALE Member

offers both insured and self-insured coverage, complete

Part III only for employees who enroll in the self-insured

coverage.

An ALE Member with a self-insured major medical plan

and a health reimbursement arrangement (HRA) that has

15

an individual who enrolls in both types of minimum

essential coverage is required to report the individual’s

coverage under only one of the arrangements in Part III.

An ALE Member with an insured major medical plan and

an HRA that has an individual who enrolls in both types of

minimum essential coverage is not required to report in

Part III the HRA coverage of an individual if the individual

is eligible for the HRA because the individual enrolled in

the insured major medical plan. An ALE Member with an

HRA must report coverage under the HRA in Part III for

any individual who is not enrolled in a major medical plan

of the ALE Member (for example, if the individual is

enrolled in a group health plan of another employer (such

as spousal coverage) or if the ALE Member provides an

individual coverage HRA). For additional information on

the reporting of supplemental coverage, see Proposed

Regulations section 1.6055-1(d)(2) and (3).

If the ALE Member is completing Part III, enter “X” in the

checkbox in Part III. If the ALE Member is not completing

Part III, do not enter “X” in the checkbox in Part III.

This part must be completed by an ALE Member

offering self-insured health coverage for any individual

who was an employee for 1 or more calendar months of

the year, whether full-time or non-full-time, and who

enrolled in the coverage. The employee (if enrolled in

self-insured coverage) should be listed on line 18; any

other family members who enrolled in coverage offered to

the employee should be listed on subsequent lines.

Tip: All employee family members that are covered

individuals through the employee’s enrollment (for

example, because the employee elected family coverage)

must be included on the same form as the employee (or

any other individual to whom the offer was made). For

example, if the employee is offered family coverage by

their employer under a self-insured health plan and enrolls

in the family coverage, the employee and the employee’s

family members that are covered under the plan must all

be reported on the same Form 1095-C.

If two or more employees employed by the same ALE

Member are spouses or an employee and their

dependent, and one employee enrolled in a coverage

option under the plan that also covered the other

employee(s) (for example, one employee spouse enrolled

in family coverage that provided coverage to the other

employee spouse and their employee dependent child),

the enrollment information should be reflected only on

Form 1095-C for the employee who enrolled in the

coverage. (However, it would report the other employee

family members as covered individuals.)

Coverage of nonemployee. This part may be

completed by an ALE Member offering self-insured health

coverage for any other individual who enrolled in the

coverage under the plan for 1 or more calendar months of

the year but was not an employee for any calendar month

of the year, such as a nonemployee director, a retired

employee who retired in a previous year, a terminated

employee receiving COBRA continuation coverage (or

any other form of post-employment coverage) who

terminated employment during a previous year, and a

nonemployee COBRA beneficiary (but not including an

individual who obtained coverage through the employee’s

16

enrollment, such as a spouse or dependent obtaining

coverage when an employee elects COBRA continuation

coverage that is family coverage). If Form 1095-C is used

with respect to an individual who was not an employee for

any month of the calendar year, Part II must be completed

by using code 1G in the “All 12 Months” box or the

separate monthly boxes for all 12 calendar months. The

employer must report for these individuals using Form

1095-B, if it chooses not to use Form 1095-C.

Tip: If a nonemployee individual enrolls in the coverage

under a self-insured health plan, all family members that

are covered individuals because of the individual’s

enrollment must be included on the same Form 1095-B or

Form 1095-C as the individual who is offered, and enrolls

in, the coverage.

Columns (a) through (e), as applicable, must be

completed for each individual enrolled in the coverage,

including the employee reported on line 1. Enter the

nine-digit SSN or other TIN for each covered individual in

column (b). Enter a date of birth in column (c) only if an

SSN or other TIN is not entered in column (b). Column (d)

will be checked if the individual was covered for at least 1

day in every month of the year. For individuals who were

covered for some but not all months, information will be

entered in column (e) indicating the months for which

these individuals were covered.

Tip: Governmental Unit employers offering self-insured

health coverage that have delegated another

Governmental Unit (DGE) for purposes of reporting and

furnishing enrollment information (meaning the information

that otherwise would be reported on Form 1095-C, Part

III), but have not designated a DGE for purposes of

reporting and furnishing offer of coverage information

(meaning the information that is reported on Form 1095-C,

Part II), should file and furnish Forms 1095-C with a

completed Part I and Part II, but not a completed Part III,

and should not check the box indicating that the

Governmental Unit offers self-insured health coverage. In

this case, the DGE should file Forms 1094-B and 1095-B

to report enrollment information for employees on behalf

of the Governmental Unit. See FAQs on IRS.gov.

A DGE that has been delegated by a Governmental

Unit for purposes of reporting and furnishing both offer of

coverage and enrollment information (meaning the

information that would be reported on Parts II and III of

Form 1095-C) should file Forms 1094-C and 1095-C to

report the information for employees on behalf of the

Governmental Unit.

Column (a). Enter the name of each covered individual

(first name, middle initial, last name), including the

employee, if the employee is enrolled in self-insured

coverage.

Column (b). Enter the nine-digit SSN for each covered

individual, including the dashes. For covered individuals

who are not the employee listed in Part I, a taxpayer

identification number (TIN), rather than an SSN, may be

entered if the covered individual does not have an SSN, or

the field may be left blank if the covered individual does

not have a TIN.

Instructions for Forms 1094-C and 1095-C (2025)

Column (c). Enter a date of birth (YYYY-MM-DD) for the

covered individual only if column (b) is blank.

Column (d). Check this box if the individual was covered

for at least 1 day per month for all 12 months of the

calendar year.

Column (e). If the individual was not covered for all 12

months of the calendar year, check the applicable box(es)

for the month(s) in which the individual was covered for at

least 1 day in the month.

Definitions

This section contains the definitions of key terms used in

Forms 1094-C and 1095-C and these instructions. For

definitions of terms not included in this section, see the

final regulations under section 4980H, T.D. 9655, 2014-9

I.R.B. 541, at IRS.gov/irb/2014-9_IRB/ar05.html and

section 6056, T.D. 9661, 2014-13 I.R.B. 855, at

IRS.gov/irb/2014-13_IRB/ar09.html.

Affordability. Generally, the lowest cost silver plan for the

employee based on the employee’s residence is used to

determine affordability. The ZIP code for the employee’s

residence is used to identify the applicable lowest cost

silver plan to determine affordability.

Aggregated ALE Group. An Aggregated ALE Group

refers to a group of ALE Members treated as a single

employer under section 414(b), 414(c), 414(m), or 414(o).

An ALE Member is a member of an Aggregated ALE

Group for a month if it is treated as a single employer with

the other members of the group on any day of the

calendar month. If an ALE is made up of only one person

or entity, that one ALE Member is not a part of an

Aggregated ALE Group. Government entities and

churches or conventions or associations of churches may

apply a reasonable, good faith interpretation of the

aggregation rules under section 414 in determining their

status as an ALE or member of an Aggregated ALE

Group. For more information on how the aggregation rules

apply to government entity employers, see Notice

2015-87, Q&A 18, at IRS.gov/irb/2015-52_IRB/ar11.html.

Applicable Large Employer (ALE). An ALE is, for a

particular calendar year, any single employer, or group of

employers treated as an Aggregated ALE Group, that

employed an average of at least 50 full-time employees

(including full-time equivalent employees) on business

days during the preceding calendar year. For purposes of

determining an employer’s average number of employees,

disregard an employee for any month in which the

employee has coverage under a plan described in section

4980H(c)(2)(F) (generally, TRICARE or Veterans

Administration coverage). A new employer (that is, an

employer that was not in existence on any business day in

the prior calendar year) is an ALE for the current calendar

year if it reasonably expects to employ, and actually does

employ, an average of at least 50 full-time employees

(including full-time equivalent employees) on business

days during the current calendar year. For information on a

special rule for certain employers with seasonal workers,

see the final regulations under section 4980H and FAQs

on IRS.gov.

Instructions for Forms 1094-C and 1095-C (2025)

Applicable Large Employer Member (ALE Member).

An ALE Member is a single person or entity that is an

ALE, or if applicable, each person or entity that is a

member of an Aggregated ALE Group. A person or entity

that does not have employees or only has employees with

no hours of service (for example, only employees whose

entire service consists of work outside of the United

States that does not count as hours of service under

section 4980H) is not an ALE Member.

Bona fide volunteer. A bona fide volunteer is an

employee of a government entity or tax-exempt

organization whose only compensation from that entity or

organization is (1) reimbursement for (or reasonable

allowance for) reasonable expenses incurred in the

performance of services by volunteers, or (2) reasonable

benefits (including length of service awards), and nominal

fees, customarily paid by similar entities in connection with

the performance of services by volunteers.

COBRA continuation coverage. COBRA continuation

coverage is health coverage that is required to be offered

under the Consolidated Omnibus Budget Reconciliation

Act of 1986 (COBRA) in certain circumstances in which

an employee or other individual covered under a health

plan loses eligibility for coverage under that health plan

(for example, because the employee terminates

employment or has a reduction in hours). For purposes of

these instructions, COBRA continuation coverage also

includes coverage required under any other federal or

state law that provides continuation coverage comparable

to that provided under COBRA. For additional details, see

section 4980B and Regulations sections 54.4980B-1

through 54.4980B-10.

Dependent. A dependent is an employee’s child,

including a child who has been legally adopted or legally

placed for adoption with the employee, who has not

reached age 26. A child reaches age 26 on the 26th

anniversary of the date the child was born and is treated

as a dependent for the entire calendar month during which

they reach age 26. For this purpose, a dependent does

not include stepchildren, foster children, or a child that

does not reside in the United States (or a country

contiguous to the United States) and who is not a U.S.

citizen or national. For this purpose, a dependent does not

include a spouse.

Designated Governmental Entity (DGE). A DGE is a

person or persons that are part of or related to the

Governmental Unit that is the ALE Member and that is

appropriately designated for purposes of these reporting

requirements. For a Governmental Unit that has delegated

some or all of its reporting responsibilities to a DGE for

some or all of its employees, one Authoritative Transmittal

must still be filed for that Governmental Unit reporting

aggregate employer-level data for all employees of the

Governmental Unit (including those for whom the

Governmental Unit has delegated its reporting

responsibilities). For more information, see Authoritative

Transmittal for Employers Filing Multiple Forms 1094-C,

earlier.

Eligible employer-sponsored plan. An eligible

employer-sponsored plan refers to group health coverage

for employees under (1) a governmental plan, such as the

17

Federal Employees Health Benefits Program (FEHB); (2)

an insured plan or coverage offered in the small or large

group market within a state; (3) a grandfathered health

plan offered in a group market; or (4) a self-insured group

health plan for employees, including an individual

coverage HRA.

Employee. An employee is an individual who is an

employee under the common-law standard for

determining employer–employee relationships. An

employee does not include a sole proprietor, a partner in a

partnership, an S corporation shareholder who owns at

least 2% of the S corporation, a leased employee within

the meaning of section 414(n), or a worker that is a

qualified real estate agent or direct seller.

If an employee is an employee of more than one ALE

Member of the same Aggregated ALE Group during a

calendar month, the employee is treated as an employee

of the ALE Member for whom the employee has the

greatest number of hours of service for that calendar

month; if the employee has an equal number of hours of

service for two or more ALE Members of the same

Aggregated ALE Group for the calendar month, those ALE

Members must treat one of the ALE Members as the

employer of that employee for that calendar month. See

One Form 1095-C for Each Employee of Each Employer

for a discussion of reporting in these circumstances. See

Pub.15-A, Employer’s Supplemental Tax Guide, for more

information on determining who is an employee.

Note: In certain circumstances, an employee may have a

break in service (including a break in service due to a

termination of employment) during which the individual

does not earn hours of service but, upon beginning to

earn hours of service again, the ALE Member must treat

the individual as a continuing employee rather than a new

hire for purposes of certain rules under the regulations

under section 4980H. See Regulations sections

54.4980H-3(c)(4) and 54.4980H-3(d)(6). These rules do

not impact whether the individual was an employee during

the break in service, so the individual should only be

treated as an employee during the break in service for

purposes of reporting if the individual remained an

employee during that period (and had not terminated

employment with the ALE Member). For example, an

employee on unpaid leave during the break in service

would be treated as an employee for reporting purposes

during the break in service, while a former employee

whose employment had been terminated during the break

in service would not be treated as an employee for

reporting purposes.

Employee Required Contribution. The Employee

Required Contribution is the employee’s share of the

monthly cost for the lowest-cost, self-only minimum

essential coverage providing minimum value that is

offered to the employee by the ALE Member. The

employee share is the portion of the monthly cost that

would be paid by the employee for self-only coverage,

whether paid through salary reduction or otherwise.

For purposes of determining the amount of the

employee’s share of the monthly cost, an ALE Member

may divide the total cost to the employee for the plan year

by the number of months in the plan year. This monthly

18

amount of the employee’s share of the cost would then be

reported for any months of that plan year that fall within

the 2025 calendar year. For example, if the plan year

begins January 1, the ALE Member may determine the

amount to report for each month by taking the total annual

employee cost for all 12 months and dividing by 12. If the

plan year begins April 1, the ALE Member may determine

the amount to report for January through March 2025, by

taking the total annual employee cost for the plan year

ending March 31, 2025, and dividing by 12 (and reporting

that amount for January, February, and March 2025).

Then, the ALE Member may determine the monthly

amount for April through December 2025 by taking the

total annual employee cost for the plan year ending March

31, 2025, and dividing by 12 (and reporting that amount

for April through December 2025).

The Employee Required Contribution may not be the

amount the employee paid for coverage. For additional

rules on determining the amount of the Employee

Required Contribution, including for cases in which an

ALE Member makes available certain HRA contributions,

cafeteria plan contributions, wellness program incentives,

and opt-out payments, see Regulations sections

1.5000A-3(e)(3)(ii) and 1.36B-2(c)(3)(v)(A). Also see

Notice 2015-87.

Special rules apply for individual coverage HRAs.

Generally, the Employee Required Contribution for the

individual coverage HRA means the required HRA

contribution, as defined in Regulations section 1.36B-2(c)

(5)(ii). However, for purposes of the individual coverage

HRA safe harbors in Proposed Regulations section

54.4980H-5(f), the required contribution is determined

based on the applicable lowest cost silver plan, as defined

in Proposed Regulations 54.4980H-5(f)(7)(iii), and the

monthly premium for the applicable lowest cost silver plan

is determined based on the employee’s age, as defined in

Proposed Regulations 54.4980H(f)(7)(i), and the

employee’s applicable location, as defined in Proposed

Regulations 54.4980H(f)(7)(ii).

For an employee offered an individual coverage HRA,

the Employee Required Contribution is the excess of the

monthly premium for the applicable lowest cost silver plan

based on the employee’s applicable age over the monthly

individual coverage HRA amount (generally, the annual

individual coverage HRA amount divided by 12).

Applicable lowest cost silver plan. Generally, the

lowest cost silver plan for an employee for a calendar

month is the lowest cost silver plan for self-only coverage

of the employee offered through the Exchange for the ZIP

code of the employee’s applicable location for the month.

If there are different lowest cost silver plans in different

parts of a rating area, an employee’s applicable lowest

cost silver plan is the lowest cost silver plan in the part of

the rating area in which the employee’s applicable location

is located. The lowest cost silver plan for an employee is

the lowest cost silver plan for the lowest age band in the

individual market for the employee’s applicable location.

For more information, see Employer Lowest Cost Silver

Plan Premium Look-up Table.

Applicable age. For an employee who is or will be

eligible for an individual coverage HRA on the first day of

the plan year, the employee’s applicable age for the plan

Instructions for Forms 1094-C and 1095-C (2025)

year is the employee’s age on the first day of the plan year.

For an employee who becomes eligible during the plan

year, the employee’s applicable age for the remainder of

the plan year is the employee’s age on the date the

individual coverage HRA can first become effective for

that employee. Note that for non-calendar year plans or for

employees who become eligible during the plan year, the

applicable age may not be the age reported in Part II of

Form 1095-C.

Applicable location. An employee’s applicable

location is where the employee resides for the calendar

month, or if the ALE Member is applying the location safe

harbor, the employee’s primary site of employment for the

calendar month.

Employer. For purposes of these instructions, an

employer is the person that is the employer of an

employee under the common-law standard for

determining employer–employee relationships and that is

subject to the employer shared responsibility provisions of

section 4980H (these employers are referred to as ALE

Members). For more information on which employers are

ALE Members, see the definitions of Applicable Large

Employer (ALE) and Applicable Large Employer Member

(ALE Member).

Full-time employee. For purposes of Forms 1094-C and

1095-C, the term “full-time employee” means a full-time

employee, as defined under section 4980H and the

related regulations, rather than any other definition of that

term that the ALE Member may use for other purposes.

Accordingly, a full-time employee is an employee who, for

a calendar month, is determined to be a full-time

employee under either the monthly measurement method

or the look-back measurement method (as applicable to

that employee). The monthly measurement method and

the look-back measurement method are the two methods

provided under the section 4980H regulations for

determining whether an employee has sufficient hours of

service to be a full-time employee. Under the monthly

measurement method, a full-time employee is an

employee who was employed an average of at least 30

hours of service per week with the ALE Member during a

calendar month. Under the look-back measurement

method, an employee is a full-time employee for each

month of the stability period selected by the ALE Member

if the employee was employed an average of at least 30

hours of service per week with the ALE Member during

the measurement period preceding that stability period.

(The look-back measurement method for identifying

full-time employees is available only for purposes of

determining and computing liability under section 4980H,

and not for purposes of determining if the employer is an

Applicable Large Employer.) For purposes of both

methods, 130 hours of service in a calendar month is

treated as the monthly equivalent of at least 30 hours of

service per week.

An ALE Member must report complete information for

all 12 months of the calendar year for any of its employees

who were full-time employees for 1 or more months of the

calendar year. For more information on the identification of

full-time employees, including discussion of the monthly

measurement method and the look-back measurement

method, and the rules for when an ALE Member may use

Instructions for Forms 1094-C and 1095-C (2025)

one or both methods, see Regulations sections

54.4980H-1(a)(21) and 54.4980H-3, and Notice 2014-49,

2014-41 I.R.B. 66 (describing a proposed approach to the

application of the look-back measurement method in

situations in which the measurement period applicable to

an employee changes).

Note: A former employee (for example, a retiree) is not a

full-time employee for any month after termination of

employment with the ALE Member. However, if the former

employee was a full-time employee for any month of the

calendar year (for example, before retiring mid-year), the

ALE Member must complete information in Part II of Form

1095-C for all 12 months of the calendar year, using the

appropriate codes.

Tip: An ALE Member need not file a Form 1095-C for an

individual who for each month of a calendar year is either

not an employee of the ALE Member or is an employee in

a Limited Non-Assessment Period with respect to section

4980H(b). However, for the months in which the employee

was an employee of the ALE Member, such an employee

would be included in the total employee count reported on

Form 1094-C, Part III, column (c). Also, if during the

Limited Non-Assessment Period the employee enrolled in

coverage under a self-insured, employer-sponsored plan,

the ALE Member must file a Form 1095-C for the

employee to report coverage information for the year.

Full-time equivalent employees. A combination of

employees, each of whom individually is not treated as a

full-time employee because they are not employed on

average at least 30 hours of service per week with an

employer, but who, in combination, are counted as the

equivalent of a full-time employee solely for purposes of

determining whether the employer is an ALE. For rules on

how to determine full-time equivalent employees, see

Regulations section 54.4980H-2(c).

Governmental Unit and Agency or Instrumentality of

a Governmental Unit. A Governmental Unit is the

government of the United States, any state or political

subdivision thereof, or any Indian tribal government (as

defined in section 7701(a)(40)) or subdivision of an Indian

tribal government (as defined in section 7871(d)). For

purposes of these instructions, references to a

Governmental Unit include an Agency or Instrumentality of

a Governmental Unit. Until guidance is issued that defines

the term “Agency or Instrumentality of a Governmental

Unit” for purposes of section 6056, an entity may

determine whether it is an Agency or Instrumentality of a

Governmental Unit based on a reasonable and good faith

interpretation of existing rules relating to agency or

instrumentality determinations for other federal tax

purposes.

Health coverage. As used in these instructions, health

coverage refers to minimum essential coverage, unless

otherwise indicated.

Hours of service. An hour of service is each hour for

which an employee is paid, or entitled to payment, for the

performance of duties for the employer, and each hour for

which an employee is paid, or entitled to payment, for a

period of time during which no duties are performed due

to vacation, holiday, illness, incapacity (including

19

disability), layoff, jury duty, military duty, or leave of

absence. An hour of service does not include any hour of

service performed as a bona fide volunteer of a

government entity or tax-exempt entity, as part of a

Federal Work-Study Program (or a substantially similar

program of a state or political subdivision thereof) or to the

extent the compensation for services performed

constitutes income from sources outside the United

States. For additional rules for determining hours of

service, see Regulations sections 54.4980H-1(a)(24) and

54.4980H-3(b), and Notice 2015-87, Q&A 14, at

IRS.gov/irb/2015-52_IRB#NOT-2015-87. See section VI of

the preamble to the section 4980H regulations for a

discussion of determination of hours of service for

categories of employees for whom the general rules for

determining hours of service may present special

difficulties (including adjunct faculty and commissioned

salespeople) and certain categories of work hours

associated with some positions of employment, including

layover hours (for example, for certain airline employees),

on-call hours, and work performed by an individual who is

subject to a vow of poverty as a member of a religious

order.

Individual coverage HRA. An HRA is a type of

account-based health plan that employers can use to

reimburse employees for their medical care expenses. An

individual coverage HRA is an HRA integrated with

individual health insurance coverage or Medicare, subject

to certain conditions. For more information about

individual coverage HRAs, see T.D. 9867 and IRS.gov/

Newsroom/Health-Reimbursement-Arrangements-HRAs.

Limited Non-Assessment Period. A Limited

Non-Assessment Period generally refers to a period

during which an ALE Member will not be subject to an

assessable payment under section 4980H(a) and, in

certain cases, section 4980H(b), for a full-time employee,

regardless of whether that employee is offered health

coverage during that period.

The first 5 periods described below are Limited

Non-Assessment Periods with respect to sections

4980H(a) and 4980H(b) only if the employee is offered

health coverage by the first day of the first month following

the end of the period. Also, the first 5 periods described

below are Limited Non-Assessment Periods for section

4980H(b) only if the health coverage that is offered at the

end of the period provides minimum value. For more

information on Limited Non-Assessment Periods and the

application of section 4980H, see Regulations section

54.4980H-1(a)(26).

• First year as ALE period. January through March of the

first calendar year in which an employer is an ALE, but

only for an employee who was not offered health coverage

by the employer at any point during the prior calendar

year.

• Waiting period under the monthly measurement

method. If an ALE Member is using the monthly

measurement method to determine whether an employee

is a full-time employee, the period beginning with the first

full calendar month in which the employee is first

otherwise (but for completion of the waiting period) eligible

for an offer of health coverage and ending no later than 2

20

full calendar months after the end of that first calendar

month.

• Waiting period under the look-back measurement

method. If an ALE Member is using the look-back

measurement method to determine whether an employee

is a full-time employee and the employee is reasonably

expected to be a full-time employee at their start date, the

period beginning on the employee’s start date and ending

not later than the end of the employee’s third full calendar

month of employment.

• Initial measurement period and associated

administrative period under the look-back measurement

method. If an ALE Member is using the look-back

measurement method to determine whether a new

employee is a full-time employee, and the employee is a

variable hour employee, seasonal employee, or part-time

employee, the initial measurement period for that

employee and the administrative period immediately

following the end of that initial measurement period.

• Period following change in status that occurs during

initial measurement period under the look-back

measurement method. If an ALE Member is using the

look-back measurement method to determine whether a

new employee is a full-time employee, and, as of the

employee’s start date, the employee is a variable hour

employee, seasonal employee, or part-time employee,

but, during the initial measurement period, the employee

has a change in employment status such that, if the

employee had begun employment in the new position or

status, the employee would have reasonably been

expected to be a full-time employee, the period beginning

on the date of the employee’s change in employment

status and ending not later than the end of the third full

calendar month following the change in employment

status. If the employee is a full-time employee based on

the initial measurement period and the associated stability

period starts sooner than the end of the third full calendar

month following the change in employment status, this

Limited Non-Assessment Period ends on the day before

the first day of that associated stability period.

• First calendar month of employment. If the employee’s

first day of employment is a day other than the first day of

the calendar month, then the employee’s first calendar

month of employment is a Limited Non-Assessment

Period.

Minimum essential coverage (MEC). Although various

types of health coverage may qualify as MEC, for

purposes of these instructions, MEC refers to health

coverage under an eligible employer-sponsored plan. An

individual coverage HRA is a self-insured group health

plan and an eligible employer sponsored plan. For more

details on MEC, see Minimum essential coverage in Pub.

974.

Minimum value. A plan provides minimum value if the

plan pays at least 60% of the costs of benefits for a

standard population and provides substantial coverage of

in-patient hospitalization services and physician services.

An individual coverage HRA that is affordable is treated as

providing minimum value.

Offer of health coverage. An ALE Member makes an

offer of coverage to an employee if it provides the

employee an effective opportunity to enroll in the health

Instructions for Forms 1094-C and 1095-C (2025)

coverage (or to decline that coverage) at least once for

each plan year. For this purpose, the plan year must be 12

consecutive months unless a short plan year of less than

12 consecutive months is permitted for a valid business

purpose. An ALE Member makes an offer of health

coverage to an employee for the plan year if it continues

the employee’s election of coverage from a prior year but

provides the employee an effective opportunity to opt out

of the health coverage. If an ALE Member provides health

coverage to an employee but does not provide the

employee an effective opportunity to decline the coverage,

the ALE Member is treated as having made an offer of

health coverage to the employee only if that health

coverage provides minimum value and does not have an

Employee Required Contribution for the coverage for any

calendar month of more than 9.5% (as adjusted) of a

monthly amount determined as the mainland federal

poverty line for a single individual for the applicable

calendar year, divided by 12.

For purposes of reporting, an offer to a spouse includes

an offer to a spouse that is subject to one or more

reasonable, objective conditions, regardless of whether

the reasonable, objective conditions are satisfied. For

example, an offer of coverage that is available to a spouse

only if the spouse certifies that the spouse does not have

access to health coverage from another employer is

treated as an offer of coverage to the spouse for reporting

purposes. Note that this treatment is for reporting

purposes only, and will generally not affect the spouse’s

eligibility for the premium tax credit if the spouse did not

meet the condition and therefore did not have an actual

offer of coverage. A conditional offer to a spouse is

reported by entering code 1J or 1K (as applicable) on

line 14 of Form 1095-C. See the instructions for line 14 for

more information. An offer to a dependent does not

include an offer to a dependent that is subject to one or

more reasonable, objective conditions unless the

dependent satisfies the conditions and the dependent

actually had an offer of coverage. In addition, an offer of

coverage is treated as made to an employee’s

dependents only if the offer of coverage is made to an

unlimited number of dependents regardless of the actual

number of dependents, if any, an employee has during

any particular calendar month.

An ALE Member offers health coverage for a month

only if it offers health coverage that would provide

coverage for every day of that calendar month. For

reporting purposes, this means that an offer of coverage

does not occur for a month if an employee’s employment

terminates before the last day of a calendar month and the

health coverage also ends before the last day of that

calendar month (or for an employee who did not enroll in

coverage, the coverage would have ended if the employee

had enrolled in coverage). However, see the description of

Code Series 2—Section 4980H Safe Harbor Codes and

Other Relief for Employers, code 2B, which may be

applicable in these circumstances to indicate that the ALE

Member is treated as having offered coverage for the

entire month for purposes of section 4980H.

An ALE Member offers health coverage to an employee

if it, or another employer in the Aggregated ALE Group, or

a third party, such as a multiemployer or single employer

Taft-Hartley plan, a multiple employer welfare

Instructions for Forms 1094-C and 1095-C (2025)

arrangement (MEWA), or, in certain cases, a staffing firm,

offers health coverage on behalf of the employer. See

Regulations sections 54.4980H-4(b)(2) and

54.4980H-5(b).

Tip: Interim Guidance Regarding Multiemployer

Arrangements. An ALE Member is treated as offering

health coverage to an employee if the ALE Member is

required by a collective bargaining agreement or related

participation agreement to make contributions for that

employee to a multiemployer plan that offers, to

individuals who satisfy the plan’s eligibility conditions,

health coverage that is affordable and provides minimum

value, and that also offers health coverage to those

individuals’ dependents. For more information, see

section XV.E of the preamble to the final regulations under

section 4980H. This relief is referred to as the

“multiemployer arrangement interim guidance” and the

“multiemployer interim rule relief” in these instructions.

Qualifying Offer. A Qualifying Offer is an offer of MEC

providing minimum value to one or more full-time

employees for all calendar months during the calendar

year for which the employee was a full-time employee for

whom a section 4980H assessable payment could apply,

with an Employee Required Contribution for each month,

not exceeding 9.5 % (as adjusted) of the mainland single

federal poverty line divided by 12, provided that the offer

includes an offer of MEC to the employee’s spouse and

dependents (if any).

Privacy Act and Paperwork Reduction Act Notice. We

ask for the information on these forms to carry out the

Internal Revenue laws of the United States and the Patient

Protection and Affordable Care Act. Our legal right to ask

for the information on this form is Internal Revenue Code

sections 6055, 6056, 4980H, and their regulations. We

request it to confirm that you are providing your

employees offers of, and enrollment in, health coverage

and to determine the employer shared responsibility

payments and eligibility of your employees for premium

tax credits. If you do not provide this information, we may

be unable to determine whether your employees are

entitled to premium tax credits. Providing false or

fraudulent information may subject you to penalties. We

may disclose this information to the Department of Justice

for civil or criminal litigation and to cities, states, and the

District of Columbia for use in administering their tax laws.

We may also disclose this information to other countries

under a tax treaty, to federal and state agencies to enforce

federal nontax criminal laws, or to federal law enforcement

and intelligence agencies to combat terrorism.

You are not required to provide the information

requested on a form that is subject to the Paperwork

Reduction Act unless the form displays a valid OMB

control number. Books or records relating to a form or its

instructions must be retained as long as their contents

may become material in the administration of any Internal

Revenue law. Generally, tax returns and return information

are confidential, as required by section 6103.

The time needed to complete and file this form will vary

depending on individual circumstances. The estimated

average time is:

21

Form 1094-C. . . . . . . . . . . . . . . . . .

4 hr.

Form 1095-C. . . . . . . . . . . . . . . . . .

12 min.

If you have comments concerning the accuracy of

these time estimates or suggestions for making this form

22

simpler, we would be happy to hear from you. You can

send us comments from IRS.gov/FormComments. Or you

can write to the Internal Revenue Service, Tax Forms and

Publications Division, 1111 Constitution Ave. NW,

IR-6526, Washington, DC 20224. Don’t send the form to

this office.

Instructions for Forms 1094-C and 1095-C (2025)