6055 Reporting Requirements: Forms, Deadlines, and Corrections

Section 6055 reporting requirements apply to every entity that provides minimum essential coverage (MEC): health insurance issuers, government agencies, and self-insured employers must file annual returns with the IRS identifying who was covered and for which months, and must make a statement available to each covered individual.¹ The federal individual mandate penalty dropped to $0 for months after December 2018, but the reporting itself is unchanged and fully enforced.²

Who Files, and on Which Form

The obligation follows whoever actually provides the coverage. Two paths exist, and which one you take turns on whether you are an Applicable Large Employer (ALE) and whether your plan is self-insured.

Health insurance issuers, government programs (Medicaid, CHIP, Medicare, TRICARE), and self-insured employers that are not ALEs file Form 1095-B for each covered individual, with a Form 1094-B transmittal summarizing the batch.³⁴ Company size is irrelevant here. A 15-person business running a self-insured plan has the same 1095-B duty as a national carrier.

An ALE is any employer that averaged at least 50 full-time employees, including full-time equivalents, in the prior calendar year.⁵ ALEs file Form 1095-C for every employee who was full-time in any month, transmitted with Form 1094-C.⁶ If the ALE is self-insured, Part III of the 1095-C picks up the Section 6055 information, and no separate 1095-B is filed for those employees. One caution for controlled groups: businesses under common ownership are counted together when testing the 50-employee threshold, so an entity that employs only a few people on its own can still be an ALE.

What Goes on Each Form

Form 1095-B

Form 1095-B has four parts. Part I identifies the coverage provider (name, address, EIN). Part II identifies the responsible individual and their Social Security number. Part III identifies the insurance issuer, if different. Part IV lists every covered individual, including dependents, with name, SSN, and the specific months of coverage. If an SSN cannot be obtained after reasonable solicitation, the filer may substitute a date of birth.⁷

Form 1095-C

Form 1095-C carries more data because it covers both the offer of coverage and, for self-insured plans, actual enrollment. Part I identifies the ALE and the employee. Part II reports the offer month by month:

Line 14 takes an offer code describing the coverage offered. Code 1A, for example, signals a qualifying offer of affordable, minimum-value coverage to the employee with at least minimum-value coverage offered to spouse and dependents.
Line 15 reports the employee’s share of the lowest-cost monthly premium for self-only minimum-value coverage.
Line 16 takes a safe-harbor code explaining why no penalty is owed if the employee received a Marketplace subsidy. Code 2C, for example, indicates the employee actually enrolled.

The IRS cross-references Line 14 and Line 16 codes against Marketplace subsidy data, and inconsistent coding is what triggers penalty assessment letters.⁸ Part III applies only to self-insured ALEs and lists the employee and each covered dependent with months of coverage. Part III data must be consistent with Part II codes: if Line 14 shows code 1H (no offer) for a month, Part III generally should not show enrollment for that same month.

Deadlines and Electronic Filing

For 2025 coverage, both the 1094-B/1095-B and the 1094-C/1095-C series must reach the IRS by February 28, 2026 if you file on paper, or March 31, 2026 if you file electronically.⁷

Almost nobody still qualifies for the paper option. Starting with tax year 2023, the IRS lowered the electronic filing threshold from 250 returns to 10 in the aggregate across all information return types.⁹ Five W-2s plus five 1095-Cs already hits that threshold.

ACA information returns go through the IRS Affordable Care Act Information Returns (AIR) system, not the FIRE system used for other information returns.¹⁰ You need to register with AIR and obtain a Transmitter Control Code before you can submit anything, so first-time filers should start that setup well ahead of the deadline.

Furnishing Statements to Covered Individuals

Reporting to the IRS is only half the job. The rules for getting a copy to the covered person differ by form.

ALEs must furnish Form 1095-C to each full-time employee by March 2, 2026 for the 2025 calendar year. The IRS automatically extends the statutory January 31 deadline to March 2, and no additional extension request is needed.⁸ Electronic delivery is allowed only if the employee affirmatively consents.

Form 1095-B filers no longer have to mail statements automatically. Under a finalized alternative method, the furnishing duty is satisfied by posting a clear, conspicuous notice on the provider’s website telling individuals they can request a copy. The notice must list an email address, a physical mailing address, and a phone number, and must remain posted through October 15 of the filing year. When someone requests a copy, the provider has 30 days to furnish it.⁷ Providers that prefer to mail statements to everyone can still do that.

Penalties for Missing or Wrong Returns

Two separate penalty sections apply. Section 6721 covers failures to file correct returns with the IRS. Section 6722 covers failures to furnish correct statements to individuals. Both can hit the same record.¹¹

For returns due in 2026, the inflation-adjusted per-return amounts under each section are:¹²

$60 if corrected within 30 days of the deadline
$130 if corrected after 30 days but by August 1
$340 if filed after August 1 or not filed at all
$680 for intentional disregard, with no annual cap

Because the two sections stack, a single record left entirely unfiled and unfurnished can cost $680 ($340 under 6721 plus $340 under 6722) before intentional disregard is even considered. Annual caps depend on filer size. Businesses and government entities with average annual gross receipts above $5 million face a maximum of $4,098,500 per year for late-filed returns; small businesses at or under $5 million in gross receipts face a cap of $1,366,000.¹³ Intentional disregard penalties are uncapped at any size.

Fixing Errors After You File

If you catch a mistake before the filing deadline, submit a corrected original. The IRS treats it as a replacement, and no special marking is required.

After the deadline, file a corrected Form 1095-B or 1095-C with the “CORRECTED” box checked, and send the corrected statement to both the IRS and the affected individual as soon as you find the error. Speed matters directly to cost: a fix within 30 days of the deadline drops the per-return penalty to $60 rather than $340.¹²

One shortcut worth knowing: when the only correction sits in Part III of a Form 1095-C (the covered individuals section), you do not need to file a corrected Form 1094-C transmittal. Resubmitting the corrected 1095-C is enough.⁸

1
Office of the Law Revision Counsel. 26 U.S. Code 6055 – Reporting of Health Insurance Coverage
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Office of the Law Revision Counsel. 26 U.S. Code 5000A – Requirement to Maintain Minimum Essential Coverage
3
Internal Revenue Service. Information Reporting by Providers of Minimum Essential Coverage
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Internal Revenue Service. About Form 1094-B, Transmittal of Health Coverage Information Returns
5
Internal Revenue Service. Determining if an Employer is an Applicable Large Employer
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Internal Revenue Service. Questions and Answers About Information Reporting by Employers on Form 1094-C and Form 1095-C
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Internal Revenue Service. Instructions for Forms 1094-B and 1095-B
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Internal Revenue Service. Instructions for Forms 1094-C and 1095-C
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Internal Revenue Service. Topic No. 801 Who Must File Information Returns Electronically
10
Internal Revenue Service. Affordable Care Act Information Returns (AIR)
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Internal Revenue Service. Information Return Penalties
12
Internal Revenue Service. Rev. Proc. 2024-40
13
Internal Revenue Service. 20.1.7 Information Return Penalties