Form 1094-B: Filing Requirements, E-Filing, and Penalties

Form 1094-B is the one-page transmittal cover sheet that a non-ALE provider of minimum essential coverage files with the IRS to accompany a batch of Forms 1095-B. It carries your organization’s identifying information and a count of the 1095-B statements in the batch. Nothing about individual coverage goes on it; that data lives on the attached 1095-B forms. Getting the transmittal right matters because the IRS uses it to reconcile what you sent, and per-return penalties apply to late or incorrect filings.

Who Files Form 1094-B

Federal law requires every person or entity that provides minimum essential coverage during a calendar year to file an information return reporting that coverage.1Office of the Law Revision Counsel. 26 USC 6055 – Reporting of Health Insurance Coverage The 1094-B/1095-B series is for filers that are not Applicable Large Employers. An ALE is an organization that averaged 50 or more full-time employees, counting full-time equivalents, during the prior calendar year. ALEs use the 1094-C/1095-C series instead, regardless of plan type.2Internal Revenue Service. Instructions for Forms 1094-B and 1095-B

Typical 1094-B filers are:

  • Small employers (fewer than 50 full-time employees) that sponsor a self-insured health plan and report coverage for enrolled individuals.
  • Health insurance issuers and carriers reporting the fully insured coverage they provide.
  • Government programs, including Medicaid, Medicare, and CHIP, transmitting their coverage data.

If your organization’s ALE status is uncertain, settle that question first. It decides which form series you use and drives every downstream step.

How to Complete the Form Line by Line

Form 1094-B is short. Every field is either identification or a summary count.

  • Lines 1 and 2: Your organization’s full legal name and nine-digit Employer Identification Number. Both must match what the IRS has on file for your entity.
  • Lines 3 and 4: The name and telephone number of a contact person who can respond to IRS inquiries about the submission.
  • Lines 5 through 8: The complete mailing address for IRS correspondence. Use a P.O. box number if that is where your mail goes.2Internal Revenue Service. Instructions for Forms 1094-B and 1095-B
  • Line 9: The total number of Forms 1095-B transmitted with this 1094-B. The count must exactly match the physical or electronic batch.2Internal Revenue Service. Instructions for Forms 1094-B and 1095-B

Line 9 is where mistakes tend to happen, particularly when batches are split or last-minute additions come in. Verify it against the actual stack before you submit. E-file software should calculate it automatically; check it anyway.

Before you file, consider validating the name-and-TIN combinations on the underlying 1095-B forms. The IRS runs a free TIN Matching program through e-Services that lets you check combinations interactively or in bulk, and catching mismatches ahead of the deadline prevents penalty-generating errors on the returns you transmit.3Internal Revenue Service. Taxpayer Identification Number (TIN) Matching

Filing Deadlines and Recipient Statements

Two deadlines apply, and they are separate obligations.2Internal Revenue Service. Instructions for Forms 1094-B and 1095-B

  • Paper filing with the IRS: February 28 of the year following coverage.
  • Electronic filing with the IRS: March 31 of the year following coverage.
  • Furnishing the 1095-B statement to each covered individual: March 2 of the year following coverage. For the 2025 coverage year, that means recipient copies by March 2, 2026.

If either IRS date falls on a weekend or federal holiday, it shifts to the next business day. The recipient statement is a copy of the 1095-B itself, and missing that furnishing deadline carries its own penalties parallel to the IRS filing penalties.1Office of the Law Revision Counsel. 26 USC 6055 – Reporting of Health Insurance Coverage

Need more time? Form 8809 gets you an automatic 30-day extension of your IRS filing deadline, provided you submit it by the original due date. You can file it online through the FIRE system.4Internal Revenue Service. About Form 8809, Application for Extension of Time to File Information Returns The extension does not push the March 2 recipient statement deadline.

Electronic Filing and the Paper Exception

The IRS requires electronic filing from any entity that submits 10 or more information returns in a calendar year. The 10-return threshold is aggregate, counting W-2s, 1099s, and every other information return type together, not just the 1094-B/1095-B series. Most organizations filing 1094-B clear it.2Internal Revenue Service. Instructions for Forms 1094-B and 1095-B

Electronic submissions go through the IRS Affordable Care Act Information Returns (AIR) system.5Internal Revenue Service. Affordable Care Act Information Returns (AIR) First-time filers must apply for an ACA Transmitter Control Code before they can use it. The application requires an ID.me account for e-Services access, and once approved, your TCC appears online and arrives by mail.6Internal Revenue Service. Apply for the Affordable Care Act for Transmitter Control Code (TCC) Start early. Registration, software testing, and approval all take time, and filing season is not the moment to discover you cannot transmit.

Hardship Waiver From E-Filing

If electronic filing creates genuine hardship, Form 8508 requests a waiver. Submit it at least 45 days before the return due date.7Internal Revenue Service. Form 8508, Application for a Waiver from Electronic Filing of Information Returns Recognized grounds include undue financial hardship, a federally declared disaster affecting your business, or being in your first year of operation. Financial hardship claims must include two written cost estimates comparing electronic and paper filing; requests without them are denied automatically. Fax is the IRS’s preferred method; mail is also accepted. Filing on paper without an approved waiver exposes you to the same penalties as filing late.

Paper Filing Addresses

Filers approved to submit on paper send Form 1094-B and its attached 1095-B forms to the assigned IRS service center:2Internal Revenue Service. Instructions for Forms 1094-B and 1095-B

  • Austin, TX 73301 — for filers in Alabama, Arizona, Arkansas, Connecticut, Delaware, Florida, Georgia, Kentucky, Louisiana, Maine, Massachusetts, Mississippi, New Hampshire, New Jersey, New Mexico, New York, North Carolina, Ohio, Pennsylvania, Rhode Island, Texas, Vermont, Virginia, or West Virginia. Filers located outside the United States also use this address.
  • Department of the Treasury, Internal Revenue Service Center, P.O. Box 219256, Kansas City, MO 64121-9256 — for filers in all other states and the District of Columbia.

Correcting a Return After You’ve Filed

If you discover an error on a 1095-B already filed, prepare a complete corrected 1095-B, mark the “CORRECTED” checkbox with an X, and transmit it under a fresh Form 1094-B. Form 1094-B itself is not corrected; you use a new transmittal to send the corrected 1095-B forms.2Internal Revenue Service. Instructions for Forms 1094-B and 1095-B Furnish a corrected copy to the affected individual as well. Retroactive coverage changes, backdated COBRA elections, and similar adjustments after the fact all trigger the correction requirement.

Penalties for Late or Incorrect Filing

Penalties apply per return, and the IRS assesses them separately for failure to file with the agency and failure to furnish statements to recipients. For returns due in 2026:8Internal Revenue Service. Information Return Penalties

  • Filed up to 30 days late: $60 per return.
  • Filed 31 days late through August 1: $130 per return.
  • Filed after August 1 or not filed at all: $340 per return.
  • Intentional disregard: $680 per return, with no annual maximum.

Annual caps limit total exposure for the non-intentional tiers, and the caps are higher for organizations with average annual gross receipts above $5 million.9Internal Revenue Service. 20.1.7 Information Return Penalties The tiered structure rewards moving fast. A carrier transmitting 5,000 forms that slips past August 1 faces potential exposure of $1.7 million before the cap; catching the miss within 30 days cuts per-return liability by more than 80 percent.

The IRS can waive penalties where the failure was due to reasonable cause and not willful neglect, meaning you exercised ordinary business care and prudence but still could not comply.10Office of the Law Revision Counsel. 26 USC 6724 – Waiver; Definitions and Special Rules Recognized circumstances include natural disasters, destruction of records, serious illness or death of the person responsible for filing, and reliance on erroneous IRS advice. Lack of awareness of the requirement, or short funds alone, generally will not qualify.