What is Form 1094-C?
Form 1094-C is a document that the Internal Revenue Service (IRS) uses to collect information from Applicable Large Employers (ALEs). These employers are required to file this form when they want to provide information about the medical insurance that they made available to their full-time employees in compliance with the Affordable Care Act (ACA).
It is like a summary and a cover sheet for all the Form 1095-C that an employer submits. Each 1095-C shows the information of individual employees, but Form 1094-C is a kind of report to the IRS that contains the entire employer’s ACA compliance.
What is the Purpose of Form 1094-C?
It’s the Official Transmittal
Its primary role is to formally transmit your batch of Forms 1095-C to the IRS.
It Certifies Your Offer of Coverage
The form includes certifications about the type of health coverage you made, which helps the IRS determine if you met your responsibilities.
It Provides a Snapshot of Your Year
It summarizes your workforce size and coverage offers month-by-month, giving the IRS a clear, aggregated picture of your compliance.
Important Key Sections of Form 1094-C
Understanding each part of Form 1094-C makes your e-filing process easier.
- Part I – Applicable Large Employer Member (ALE Member)
This part is pretty simple but still very important. This section requires some basic information, including ALE member name, EIN, and Address. If you are a designated government entity, you must be reported in this section as well. - Part II – ALE Member Information
ALE member information section serves the total number of 1095-C Forms submitted (by or on behalf of the ALE Member), that include those of an Aggregated ALE Group, and certification boxes such as the Qualifying Offer Method - Part III – ALE Member Information Monthly
It indicates the total full-time employees you had each month, the overall total number of employees (including part-time), and the minimum essential coverage offering monthly under the safe harbor method - Part IV – Other ALE Members of Aggregated ALE Group
If applicable, list the other members of the aggregated employer group, including EINs.
Form 1094-B: For Small Employers & Coverage Providers
Form 1094-B vs. Form 1094-C: Key Differences
| Feature | Form 1094-B | Form 1094-C |
|---|---|---|
| IRS Code Section | Section 6055 as part of ACA act | Section 6056 as part of ACA act |
| Primary Filers | Health Insurance Companies, Government Programs (e.g., Medicare, Medicaid), Small, self-insured employers | Applicable Large Employers (ALEs) – generally those with 50+ full-time employees |
| Purpose | Transmit information about individuals with coverage | Transmit summary of employer coverage offers |
| Primary Data Reported | Months of coverage for each enrolled individual. | Offer of Coverage codes for each employee |
| Complexity | Generally simpler, acting as a basic cover sheet and summary. | Little complex, with certifications about ALE status and specific reporting methods used. |
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