Employer-Provided Health Insurance Offer and Coverage
E-file 1095-C to report the health coverage offered to full-time employees during the 2026 tax year, required of employers with 50+ full-time employees. TaxFormHero offers bulk import from Excel, secure IRS transmission, and a filing deadline of March 31, 2027. E-filing starts from $2.99 a form with no signup fee or ongoing subscription requirements.
Form 1095-C is the statement an applicable large employer gives each full-time employee, and files with the IRS, describing the health coverage it offered that employee month by month. It is how the IRS checks two separate things: whether the employer met its obligation under the employer shared responsibility rules, and whether an employee who claimed a premium tax credit on the Marketplace was entitled to it.
It reports what was OFFERED, not only what was taken up. An employee who declined the coverage still gets a 1095-C, and the months they were offered coverage still have to be coded. This is the single most common misunderstanding about the form: a nil-uptake year is not a nil-reporting year.
Employees do not attach it to their tax return and do not need it in hand to file. It is a record, and increasingly one that only has to be handed over on request.
You are an ALE for a calendar year if you averaged 50 or more full-time employees, counting full-time equivalents, across the PREVIOUS calendar year. The test looks backwards, so the headcount that decides whether you file for 2026 is the one you had in 2025.
A full-time employee is one averaging 30 hours a week, or 130 hours a month. Part-time staff are not counted as heads: their hours are added together for each month and divided by 120, and the result is the number of full-time equivalents for that month. Add the full-time count and the equivalent count for each of the twelve months, add the twelve figures, divide by twelve.
A worked example. Forty full-time staff all year, plus twenty part-timers averaging 60 hours a month each. The part-time hours come to 1,200 a month, which is 10 full-time equivalents. Forty plus ten is fifty, in every month, so the average is fifty and the employer is an ALE. Nobody in that business would describe it as having fifty full-time employees, and that is exactly why the calculation catches people out.
Companies under common ownership are aggregated for the test, so a group of small entities can be an ALE even though no single entity is close to the threshold. Each entity then files under its own EIN.
Every 1095-C has Part I and Part II. Part III depends on how you fund the plan.
Line 14 takes a Series 1 code for each month, saying what kind of offer was made: to the employee alone, to the employee and spouse, to the employee and dependants, to everyone, or no offer at all. Code 1H means no offer was made that month, and it is not a way of saying the employee turned it down.
Line 15 is the employee required contribution: the monthly cost to the employee of the LOWEST-COST self-only plan that provides minimum value, whether or not that is the plan they actually chose. It is completed only for the months whose Line 14 code calls for it, and it is left blank the rest of the time. An employer who enters the cost of the family plan the employee picked has misreported it.
Line 16 takes a Series 2 code and is the employer safe harbour line. It says why no penalty is due for that month: the person was not employed, was in a limited non-assessment period, enrolled in the coverage, or the offer was affordable under one of the three safe harbours.
Line 17 is used only with an individual coverage HRA, and holds the ZIP code that the affordability of that arrangement was measured against.
Coverage is affordable for 2026 if the employee required contribution for the lowest-cost self-only plan does not exceed 9.96% of household income, up from 9.02% for 2025. The figure is set annually in a revenue procedure.
No employer knows an employee household income, so the rules allow three safe harbours to stand in for it: the W-2 safe harbour, measured against Box 1 wages; the rate of pay safe harbour, measured against monthly pay at the start of the year; and the federal poverty line safe harbour, which is the simplest to administer and the easiest to evidence. The safe harbour you use is what the Line 16 code records.
Two separate penalties sit behind this form and they cannot both apply in the same month. The section 4980H(a) penalty applies when an ALE fails to offer coverage to substantially all full-time employees and at least one of them receives a premium tax credit. For 2026 it is $3,340 a year, charged at one twelfth a month, multiplied by the total full-time headcount less thirty.
The section 4980H(b) penalty applies when an offer was made but was unaffordable or did not provide minimum value, and it is charged only for the employees who actually received a credit. For 2026 it is $5,010 a year, again at one twelfth a month, with no thirty-employee reduction.
The arithmetic is worth doing once. An employer with 120 full-time staff that offers nothing at all faces roughly $300,000 a year under 4980H(a). The same employer whose offer is affordable for everyone but three faces about $15,000 under 4980H(b). Getting Line 14 and Line 16 right is what keeps a case in the second column.
Separately from the employer mandate, filing late or filing wrong carries information return penalties per form, on a sliding scale that depends on how quickly it is corrected, with a much higher charge where the failure was intentional.
The Paperwork Burden Reduction Act changed furnishing from a mailing obligation into a request-based one. An employer may now post a clear, conspicuous and accessible notice that 1095-C statements are available, and send a statement only to an employee who asks, rather than mailing every one.
The conditions are specific. The notice has to be up by the furnishing deadline and stay up until 15 October. It has to be written plainly, headed so that it is recognisable as a health coverage tax document, and give an email address, a postal address and a telephone number for requests. A request must then be met within 30 days, or by 31 January, whichever is later.
The Employer Reporting Improvement Act made three further changes in the same season. An employer that cannot obtain a taxpayer identification number may report a full name and date of birth instead. Consent to receive a statement electronically now lasts until the individual withdraws it in writing, rather than needing to be re-collected. And the window to answer an IRS Letter 226-J proposing a penalty went from 30 days to 90, with a six-year limit introduced on assessments under 4980H.
The filing obligation to the IRS itself did not change. Only the furnishing to employees did.
Federal filing is not always the end of it. California, the District of Columbia, Massachusetts, New Jersey and Rhode Island run their own individual coverage mandates and have their own reporting, with their own deadlines and their own portals. An employer with staff in those jurisdictions can be fully compliant federally and still be late locally.
As at October 2026 the IRS has published instructions for Forms 1094-C and 1095-C for tax year 2025 only. There is no 2026 edition yet.
So nothing on this page quotes a 2026 figure. Everything here is stated from the current instructions and from the furnishing rules actually in force, which is the honest position until the IRS issues the 2026 revision. A page printing a confident 2026 number right now is guessing.
The substantive change in force is the alternative manner of furnishing described above. When the 2026 instructions appear, this page gets read again and re-dated.
One code per month, saying what was offered and to whom. These are the ones that cover almost every filing; the full list is in the IRS instructions.
| Code | What it means | Line 15 needed? |
|---|---|---|
| 1A | Qualifying offer: minimum value, affordable on the federal poverty line safe harbour, offered to employee, spouse and dependants | No |
| 1B | Minimum value to the employee only | Yes |
| 1C | Minimum value to the employee, plus dependants but not the spouse | Yes |
| 1D | Minimum value to the employee, plus the spouse but not dependants | Yes |
| 1E | Minimum value to the employee, spouse and dependants | Yes |
| 1F | Coverage offered that does NOT provide minimum value | No |
| 1G | Not a full-time employee for any month, but enrolled in a self-insured plan. Used for all twelve months at once | No |
| 1H | No offer of coverage that month. Not a way of recording that the employee declined | No |
| 1J / 1K | Conditional offers involving the spouse | Yes |
| 1L–1U | Individual coverage HRA offers, which also require a ZIP code on Line 17 | Yes |
If Line 14 is 1H for a month, Line 16 has to explain why no penalty is due for that month — otherwise the month reads as an unexplained failure to offer.
| Code | Use it when |
|---|---|
| 2A | The person was not employed on any day of that month |
| 2B | Not a full-time employee that month, or employment ended mid-month with coverage ending too |
| 2C | Enrolled in coverage. Takes priority over almost every other code when it applies |
| 2D | In a limited non-assessment period, such as a waiting period or initial measurement period |
| 2E | Multiemployer interim relief |
| 2F | Affordable under the W-2 safe harbour (Box 1 wages) |
| 2G | Affordable under the federal poverty line safe harbour |
| 2H | Affordable under the rate of pay safe harbour |
Only one Series 2 code goes in a month. Where more than one could apply, 2C normally wins.
| 4980H(a) — no offer | 4980H(b) — bad offer | |
|---|---|---|
| Triggered by | Failing to offer coverage to substantially all full-time employees | Offering coverage that is unaffordable or lacks minimum value |
| 2026 amount | $3,340 per year, charged at 1/12 a month | $5,010 per year, charged at 1/12 a month |
| Counted on | All full-time employees, less 30 | Only employees who received a premium tax credit |
| Also needs | At least one employee receiving a premium tax credit | The same |
The two are mutually exclusive in any given month, and (b) can never exceed what (a) would have been. Affordability for 2026 is 9.96% of household income for the lowest-cost self-only plan.
Volume pricing — each band charged at its own rate
| Volume band | Charged at | Price per form |
|---|---|---|
| First 50 | forms 1–50 | $2.99 |
| Next 100 | forms 51–150 | $1.99 |
| Next 350 | forms 151–500 | $0.99 |
| Beyond 500 | every form after | $0.60 |
Optional add-ons
State Filing $0.99 / form
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Print & Mail $1.69 / form
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E-Delivery $0.19 / form
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TIN Matching $0.49 / check
Validate name/TIN pairs before filing to avoid penalties.
Included at no extra cost
W-2, W-2C, 1095-B, 1095-C forms share this tier table. Volume tiers are counted per form type within a filing, so a large batch of 1095-C reaches the cheapest band on its own.
Estimate Your Filing CostCommon questions about e-filing Form 1095-C with TaxFormHero. Still stuck? Contact our support team or browse the full FAQ page.
The furnishing deadline is a permanent 30-day extension of January 31, so in 2027 it falls one day after the paper filing date.
Filing 10 or more information returns in aggregate means e-filing is required, so the e-file date is the one that applies to most filers.
Reviewed by Nazrul Huda, MSA, IRS PTIN Holder · last reviewed
Sources: IRS, Instructions for Forms 1094-C and 1095-C (2025) · IRS, Notice 2025-15 (alternative manner of furnishing)
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