Form 1094-C — Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns
Form 1094-C is the transmittal form filed by Applicable Large Employers (ALEs — 50+ full-time equivalent employees) with the IRS along with Form 1095-C. It summarizes the employer's health coverage offerings and certifies compliance with the ACA employer mandate. For tax professionals, ACA compliance — including identifying ALE status, calculating FTEs, and avoiding the employer shared responsibility payment — is a high-value advisory service for business clients.
Key Rules and Authority
| Rule | Detail |
|---|---|
| ALE Threshold | 50+ FTEs (including part-time equivalents) |
| Form 1094-C Deadline (paper) | February 28 |
| Form 1094-C Deadline (electronic) | March 31 |
| Form 1095-C to Employees | January 31 |
| ESRP (4980H(a)) | $2,900 per FTE (2026, indexed) |
| ESRP (4980H(b)) | $4,350 per employee receiving premium tax credit |
ALE Status — How to Calculate Full-Time Equivalents
An employer is an Applicable Large Employer (ALE) if it employed an average of 50 or more full-time equivalent employees (FTEs) in the prior calendar year. Full-time employees (30+ hours per week) count as 1.0 FTE each. Part-time employees are aggregated: total part-time hours for the month ÷ 120 = part-time FTE count. For example: an employer with 40 full-time employees and 30 part-time employees each working 60 hours per month has: 40 FTEs + (30 × 60 ÷ 120) = 40 + 15 = 55 FTEs — an ALE. Seasonal workers (employed fewer than 120 days per year) are excluded from the FTE calculation if the employer would only exceed 50 FTEs due to seasonal workers.
Frequently Asked Questions
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