Applicable large employers (ALEs), employers with 50 or more full-time and full-time equivalent employees, are required to annually report to their employees and the Internal Revenue System (IRS) health insurance coverage offered to their eligible employees. Form 1095-C is sent to employees and Form 1094-C is sent to the IRS along with copies of all 1095-C forms. Small employers with self-funded insurance plans use Forms 1095-B and 1094-B instead.
On Oct. 2, 2020, the IRS announced in Notice 2020-76 that it will extend the January 31 deadline to furnish forms 1095-B and 1095-C to employees by 30 days. The current deadlines for 2020 reporting are provided below.
|Original Deadline||Extended Deadline|
|Form 1095-B (to employees)||January 31, 2021||March 2, 2021|
|Form 1095-C (to employees)||January 31, 2021||March 2, 2021|
The Notice does not extend the deadline for filing forms (including Forms 1094-B, 1095-B, 1094-C, or 1095-C) with the IRS. The dates for 2020 reporting, submitted in 2021, appear below, along with last year’s deadlines for reference.
|ACA Reporting Forms||2019 Tax Year Deadlines
(forms filed in 2020)
|2020 Tax Year Deadlines
(forms filed in 2021)
|1095-C due to employees (postmarked if mailed)||March 2, 2020||January 31, 2021 (extended to March 2, 2021)|
|1094-C and 1095-C due to IRS if paper filing||February 28, 2020||February 28, 2021|
|1094-C and 1095-C due to IRS if electronic filing||March 31, 2020||March 31, 2021|
Additionally, while the date for filing forms with the IRS was not automatically extended, employers may still seek a 30-day extension by submitting Form 8809 by the filing due date.
For more information, visit the Internal Revenue Service’s (IRS) ACA resource page for employers.