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.
