Form 1095-C Guide for Employers

What is Form 1095-C?

If you have at least 50 full-time employees (including full-time equivalent employees), you are considered an Applicable Large Employer (ALE)* according to the Affordable Care Act (ACA) and must offer full-time employees* ACA compliant health care coverage or pay a penalty. You need to report information to the IRS about the health care coverage offered to your full-time employees using Forms 1094-C and 1095-C. You must also distribute copies of Form 1095-C to your full-time employees, which contains information they may need to report as part of their income tax submission.

The IRS uses the information from Form 1095-C to administer the Employer Shared Responsibility provision. The Form also helps the IRS administer premium tax credits for any employee who qualified and enrolled for coverage at a Health Insurance Marketplace rather than enrolling in your employer plan.

*Before January 2016, employers with 50-99 full-time employees were not required to offer coverage.

What should you do next?


You must file Form 1095-C and Form 1094-C with the IRS annually, no later than March 31 if filing electronically (or February 28 if filing on paper) for the previous calendar year.

January 31

You must distribute Form 1095-C to your full-time employees annually, no later than January 31 for the previous calendar year.

Avoid extra paperwork. Notify your employees that they will be receiving Form 1095-C in January and may need information from Form 1095-C to complete their tax filing. Tap into our communications materials to educate your employees about what the form is, when they can expect it and what to do with it. Learn more and access the toolkit >

The penalty for failure to file a Form 1095-C is generally $260 per employee. The total form penalty for a calendar year generally cannot exceed $3,178,500.

If you are not an ADP client, call 855-237-2650 to learn more about how we can help. Or visit the IRS website for more information on ACA tax provisions for large employers.

Current ADP client?


If you are an ADP client using ADP Health Compliance® or ADP TotalSource®, we will file your 1095-Cs with the IRS for you, and either send them to you or distribute them to your employees directly.


ADP Workforce Now® Essential ACA includes ACA annual reporting. If you are an ADP client using Workforce Now and aren't sure if you have opted for the Essential ACA package, please contact your representative or call 855-237-2650.


If you are not an ADP client, or an ADP client not using any of these solutions, contact your representative or call 855-237-2650 to learn more about how we can help with ACA annual reporting.

ACA compliance options

For Midsized Businesses
(50-999 EMPLOYEES)

ADP Workforce Now®
Payroll, Time, Benefits, and HR

ADP TotalSource®
Professional Employment Organization (PEO)

For Large Businesses

ADP Health Compliance
Comprehensive ACA compliance


Where do I find Form 1095-C?
If you are an ADP client using ADP Health Compliance®, ADP TotalSource®, or ADP Workforce Now® with Essential ACA, ADP will prepare and file these forms for you. You can also find the final Form 1095-C on the IRS website.

What about Form 1094-C?
Form 1094-C functions as the transmittal cover sheet for your Forms 1095-C, and is only filed with the IRS—it is not distributed to your employees. Form 1094-C requires information including how many people you employ and how many Forms 1095-C you are filing. Read more about Form 1094-C on the IRS website. Generally, each FEIN will have its own Form 1094-C.

What about Form 1094-B?
You will need to file Form 1095-B only if your company is not considered an applicable large employer and is "self-insured"--meaning they pay your medical bills directly instead of paying premiums to an insurance company. If this applies to you, read more about Form 1095-B on the IRS website.

When is the deadline to file?
Similar to the applicable W-2 reporting deadline, statements should be provided annually to employees by January 31st of each calendar year. Forms must be provided to the IRS by March 31st if filing electronically (February 28th if filing on paper) for the previous calendar year.

Do I need to file electronically?
Filers of 250 or more Forms 1095-C must file electronically.