IRS Reporting: 1095 and 1094- and due dates

Employer reporting requirements and penalties for non-compliance have largely remained the same even though the individual penalty payment is no longer applicable. Forms 1094/1095-B (B Forms) and Forms 1094/1095-C (C Forms), and related instructions, for the 2019 tax year have been released and are provided below.

Employers Subject to Reporting

Applicable large employers (ALEs), who are in general, entities that employed 50 or more full-time and full-time-equivalent employees in 2018, are required to report information about the health coverage they offered or did not offer to employees for 2019. To meet this reporting requirement, the ALE must furnish Form 1095-C
to the employee or former employee and file copies, along with Form 1094-C (transmittal), with the IRS, (1094/1095C Instructions).

Employers, regardless of size, who sponsored a self-funded health plan (including level-funded) providing minimum essential coverage in 2019 are required to report coverage information about enrollees. To meet this reporting requirement, the employer must provide Form 1095-B to the primary enrollee and file copies, along with Form 1094-B (transmittal), with the IRS, (1094/1095B Instructions). Self-funded employers who also are ALEs may use Forms 1095-C and 1094-C in lieu of Forms 1095-B and 1094-B.

Due Dates

Submission to the IRS: Generally, Forms 1094-C, 1095-C, 1094-B, and 1095-B forms must be filed with the IRS by February 28 if filing on paper (or March 31 if filing electronically).  Electronic filing is mandatory for entities required to file 250 or more Forms 1095.  

Submission to employees:  In Notice 2019-63, the IRS extends the deadline for the 2020 submission from January 31 to March 2 for employers and insurers to furnish individual statements on 2019 coverage and full time employee status (Forms 1095-B and 1095-C). 

IRS Information Center for Large Employers

Frequently Asked Questions