What Are the Form 1094-C Filing Due Dates?

Form 1094-C is a transmittal document used by employers to report summary information about health insurance coverage to the Internal Revenue Service (IRS). It is filed alongside Form 1095-C, which provides details about the health coverage offered to individual employees. This reporting requirement applies to Applicable Large Employers (ALEs), generally defined as businesses with 50 or more full-time or full-time equivalent employees in the prior calendar year.

The purpose of these forms is to allow the IRS to administer the employer-shared responsibility provisions of the Affordable Care Act (ACA). The Form 1094-C serves as a cover sheet, providing the IRS with aggregate data for the employer. This includes the employer’s contact information, the total number of Forms 1095-C being filed, and certification as to whether the employer offered minimum essential coverage to its full-time employees.

Filing Deadlines

The deadlines for filing Form 1094-C with the IRS depend on the method of submission. For employers who file on paper, the due date is February 28 of the year following the calendar year of coverage. For the 2024 tax year, this deadline is February 28, 2025.

A later deadline is available for employers who file electronically. The electronic filing, or e-filing, due date for Form 1094-C is March 31 of the year after the coverage year. For the 2024 tax year, this means electronic filers must submit their forms by March 31, 2025. If any due date falls on a weekend or legal holiday, the deadline shifts to the next business day.

IRS regulations mandate electronic filing for employers who file 10 or more information returns in total during the calendar year. This rule aggregates various types of returns, such as Forms W-2 and 1099, with the ACA forms. Most ALEs are required to file electronically and must adhere to the March 31 deadline.

Requesting a Filing Extension

Employers who anticipate they will be unable to meet the standard filing deadlines can request an extension. An automatic 30-day extension of time to file Form 1094-C with the IRS is available. To obtain this extension, an employer must file Form 8809, Application for Extension of Time to File Information Returns.

This form must be submitted to the IRS on or before the original due date of the returns. No explanation or signature is required to receive the initial 30-day automatic extension.

Completing Form 8809 requires the filer’s basic information, including their name, address, and Taxpayer Identification Number (TIN). The filer must also indicate which return series they are requesting an extension for, which in this case would be the 1094/1095 series.

Form 8809 can be submitted either by mail or electronically through the IRS’s Filing Information Returns Electronically (FIRE) system. Under certain hardship conditions, an additional 30-day extension may be requested, though this is not automatic and requires a detailed explanation.

Penalties for Late Filing

Failing to file Form 1094-C by the deadline can lead to financial penalties from the IRS. The penalty amount is calculated on a per-return basis, meaning both the Form 1094-C transmittal and each individual Form 1095-C that should have been filed are counted separately.

For the 2024 tax year, the penalty is $330 per return, with a total penalty cap of $3,987,000 for the calendar year. This cap is lower for smaller businesses. The IRS may waive these penalties if an employer can demonstrate that the failure to file was due to reasonable cause and not willful neglect.

If the failure is found to be intentional, the penalty increases to $660 per return, and there is no annual maximum limit.