IRS Form 1094-C – Employer-Level Transmittal

22 September 30, 2025
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Form 1094-C functions as the transmittal “cover sheet” for an Applicable Large Employer’s (ALE) ACA information returns. It provides employer-level data to the IRS, summarizing the offers of coverage made during the year and the total number of 1095-C forms submitted.

This form is filed with the IRS only and is not distributed to employees.

Key Functions:

  • Identifies the employer and the total number of 1095-C forms submitted.
  • Reports employer-level offer and affordability information.
  • Indicates controlled group status (Aggregated ALE Group) status, if applicable.
  • Certifies special reporting methods used by the employer.
  • Serves as the authoritative transmittal when multiple 1094-Cs are filed.

Key Components of Form 1094-C

Part I – Applicable Large Employer (ALE) Member

This section captures the employer’s basic identifying information and establishes whether this filing is the authoritative transmittal for the ALE.

  • Lines 1–16: Employer name, EIN, address, and contact information.
  • Line 18 – Total Forms 1095-C Submitted:
    • Enter the total number of Forms 1095-C filed with this specific transmittal.
    • If a single 1094-C is filed for the entire organization, this number reflects the total employee count across the ALE.
    • If multiple 1094-Cs are filed (e.g., by division), this number reflects the total tied to this submission only.
  • Line 19 – Authoritative Transmittal:
    • Check this box if the filing is the “master” 1094-C for the entire ALE.
    • The authoritative transmittal reports the aggregate total of all Forms 1095-C submitted across the organization and must be filed once per ALE.

Part II – ALE Member Information

This section provides additional information about the ALE’s filing and controlled group status (if applicable).

  • Line 20 – Total Number of 1095-Cs Filed by and/or on Behalf of ALE Member:
    • This represents the total number of 1095-C forms filed for the entire ALE member (not just the batch).
  • Line 21 – Aggregated ALE Group Membership:
    • Check “Yes” if the ALE is part of a Controlled or Aggregated ALE Group under IRC §414(b), (c), (m), or (o).
    • If “Yes,” Part IV must also be completed to list all other ALE members and their EINs.
  • Line 22 – Certifications of Eligibility:
    • Employers may check applicable boxes to indicate use of special reporting methods:
      • Qualifying Offer Method: MEC providing minimum value that is affordable under the FPL safe harbor, offered to the employee, spouse, and dependents for all eligible months.
      • 98% Offer Method: Affordable MEC/MV offered to at least 98% of full-time employees. When this method is used, the employer is not required to complete the full-time employee count in Part III, Column (b).

Part III – ALE Member Information — Monthly

This section reports monthly compliance metrics used by the IRS to assess exposure to penalties under IRC §4980H.

  • Column (a): Minimum Essential Coverage Offer Indicator
    • “Yes” if MEC was offered to at least 95% of full-time employees and their dependents. This corresponds to the “A Penalty” requirement.
  • Column (b): Full-Time Employee Count
    • Number of full-time employees each month (or for all 12 months, if consistent).
  • Column (c): Total Employee Count
    • Includes full-time, part-time, and seasonal employees. Employers may use one of five permitted measurement dates each month (e.g., first day, last day, 12th day, or based on payroll periods).
  • Column (d): Aggregated Group Indicator
    • Check if the ALE was part of an Aggregated ALE Group that month.
  • Column (e): Reserved.
    • This column is not currently in use.

Part IV – Other ALE Members of Aggregated ALE Group

For employers that are part of a Controlled Group or Aggregated ALE Group – required if “Yes” was checked on Line 21.

  • Lists the names and EINs of all other ALE members within the controlled or aggregated group that existed at any point during the calendar year.
  • Ensuring this section is completed accurately is critical, as it ties together multiple entities’ filings under a single employer mandate structure.

Practical Tips

  • Authoritative Transmittal: Designate one Form 1094-C as authoritative if filing multiple.
  • Consistency Matters: The counts and indicators on 1094-C must match the correpsonding 1095-C filings.
  • Controlled Groups: Coordinate with related entities early to avoid inconsistencies in Part IV.
  • Stay Current: The IRS updates form instructions annually – always use the version for the specific reporting year.

Important Advisory for Brokers – IRS Forms are Tax Matters

Understanding ACA reporting requirements is valuable, but completing IRS Forms 1094-C and 1095-C involves making tax determinations. These are tax filings submitted directly to the IRS, and Applicable Large Employers (ALEs) should rely on their tax counsel or other qualified tax professionals to complete and file them accurately.

Brokers should not prepare or submit IRS ACA forms on behalf of employers. Your role is to understand the rules well enough to educate, guide, and flag issues—not to provide tax advice or act as the employer’s tax preparer.