Who Must File ACA Forms 1095-C and 1095-B
Under the Affordable Care Act (ACA), certain employers are required to report the health insurance coverage they provide to their employees.
In general:
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Employers with 50 or more full-time employees (including full-time equivalents) must file under IRS Section 6056.
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All self-insured employers, regardless of size, must file under IRS Section 6055.
These employers are known as Applicable Large Employers (ALEs) and are required to furnish Forms 1095-C and 1094-C to the IRS and to their employees each year.
Determining Full-Time and Full-Time Equivalent (FTE) Employees
A full-time employee is generally someone who works an average of 30 hours or more per week for more than 120 days per year.
Even if your organization has fewer than 50 full-time employees, you may still be considered an ALE when full-time equivalents (FTEs) are included.
For example:
If three employees each work 30 hours per week for four consecutive months (120 days) one after another, those three employees count as three full-time equivalents, not just one.
👉 We recommend using the Full-Time Equivalent (FTE) Calculator provided by Healthcare.gov to determine your ACA filing obligations accurately.
Applicable Large Employer (ALE) and Employer Shared Responsibility
ALEs are subject to the Employer Shared Responsibility provisions under the ACA. These provisions require qualifying employers to:
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Offer minimum essential coverage (MEC) to full-time employees and their dependents, and
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Report this coverage annually to the IRS and to employees using the proper ACA forms.
For detailed IRS guidance, refer to official IRS resources on Applicable Large Employers (ALEs) and Employer Shared Responsibility.
Filing Requirements by Form Type
Form 1095-C and Form 1094-C
(For Applicable Large Employers – Section 6056)
Employers with 50 or more full-time employees (including FTEs) must:
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Furnish Form 1095-C to each full-time employee, and
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File a Form 1094-C transmittal summary with the IRS.
These forms report details such as:
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Employer and employee Tax ID (EIN or SSN)
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Employee’s full-time status and coverage eligibility
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Coverage offer and months covered
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Premium contribution by the employee
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Dependents covered, if applicable
For detailed instructions, see the IRS Instructions for Forms 1095-C and 1094-C.
Form 1095-B and Form 1094-B
(For Self-Insured Employers and Insurance Providers – Section 6055)
Under Section 6055, insurance carriers and self-insured employers must:
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Furnish Form 1095-B to each covered individual, and
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File Form 1094-B with the IRS as a transmittal form.
These forms include:
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Employer and employee Tax ID and address information
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Details on periods of health coverage
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Dependent coverage information, if applicable
For detailed IRS instructions, refer to the Instructions for Forms 1095-B and 1094-B.
Paper vs. Electronic Filing
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Employers filing 250 or more forms are required to e-file with the IRS.
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Smaller filers may submit paper forms, although electronic filing is strongly recommended for accuracy and convenience.
Outsource1095 is an IRS-authorized e-file provider, ensuring your forms are filed securely and on time using the Affordable Care Act Information Returns (AIR) system.
State Reporting Requirements
Currently, there are no state-level reporting requirements associated with Forms 1095-C or 1095-B.
However, this may change in the future, and we continuously monitor updates to help our clients stay compliant.
Penalties for Non-Compliance
Employers who fail to file ACA forms, file late, or submit incorrect information may face significant IRS penalties.
Using a professional service like Outsource1095 helps you avoid these risks by ensuring accurate, timely, and compliant ACA submissions.
Stay Compliant with Outsource1095
Whether you’re an ALE, self-insured employer, or insurance provider, Outsource1095 can help you meet all ACA filing requirements — from data validation to printing, mailing, and e-filing with the IRS.
Contact Us Today to learn more or request a quote.
