How to Fill Out a 1095-C Form: Parts I, II, and III

To fill out a Form 1095-C, you work through three parts: Part I collects identifying information for the employer and the employee, Part II uses coded entries on Lines 14, 15, and 16 to describe the health coverage you offered for each month of the year, and Part III lists covered individuals but only if your plan is self-insured. The codes on Line 14 and Line 16 do most of the work, because they tell the IRS whether your offer was a qualifying one and whether an affordability safe harbor applies.

Gather the Data Before You Touch the Form

Accurate 1095-C reporting depends on month-by-month tracking. Before opening the form for any employee, pull together:

  • Full legal name, Social Security Number, and current mailing address as they appear on IRS records.
  • Monthly hours of service, so you know which months the employee met the 30-hour weekly or 130-hour monthly full-time threshold.
  • Coverage offer details for each month: whether an offer was made, who it covered (employee, spouse, dependents, or some combination), and start or end dates for any partial-year offers.
  • The employee’s required monthly contribution for the lowest-cost self-only plan that meets minimum value. This single number drives affordability.
  • Whether the employee actually enrolled each month.

The lowest-cost self-only contribution is the pivotal figure. For the 2026 plan year, coverage is affordable if the employee’s share does not exceed 9.96% of their household income.1Internal Revenue Service. Rev. Proc. 2025-25 Because you rarely know an employee’s household income, you will lean on one of three safe harbors reported on Line 16.

A plan meets minimum value if it covers at least 60% of the total allowed cost of benefits expected under the plan.2Internal Revenue Service. Minimum Value and Affordability Most major-carrier group plans clear this bar; non-traditional plan designs should be verified with the IRS Minimum Value Calculator.

Part I: Employer and Employee Identifiers

Part I is short, but a transposed digit here can trigger a mismatch notice and delay processing. The IRS uses these fields to tie the form to your employee’s personal return and your organization’s employer records.

Enter your employer’s legal name, Employer Identification Number, mailing address, a contact name, and a phone number. For the employee, enter their full legal name, Social Security Number, and mailing address. If an employee recently changed their name, use what the Social Security Administration has on file, not necessarily what your HR system reflects.

Part II: The Coverage Codes on Lines 14, 15, and 16

Part II is where most of the complexity lives. Lines 14, 15, and 16 work together to tell the IRS what you offered, how much it cost, and why no penalty should apply. Complete each line for every month. If the same entry applies to all twelve months, use the “All 12 Months” box instead of filling in each column.3Internal Revenue Service. Instructions for Forms 1094-C and 1095-C

Line 14: What You Offered

Line 14 takes a single code describing the coverage you offered to the employee and their family for that month. The code determines whether the IRS treats your offer as a qualifying one.4Internal Revenue Service. 2025 Form 1095-C

  • 1A — Qualifying Offer. Affordable, minimum value coverage offered to the employee, spouse, and dependents. The strongest code from a compliance standpoint.
  • 1B. Minimum value coverage offered to the employee only.
  • 1C. Minimum value coverage to the employee plus at least minimum essential coverage to dependents, but not the spouse.
  • 1D. Minimum value coverage to the employee plus at least minimum essential coverage to the spouse, but not dependents.
  • 1E. Minimum value coverage to the employee plus at least minimum essential coverage to both spouse and dependents. Unlike 1A, a 1E offer may or may not be affordable.
  • 1F. Minimum essential coverage that did not meet the minimum value standard.
  • 1H. No offer of coverage, or an offer that did not qualify as minimum essential coverage.
  • 1J. Minimum value coverage to the employee and a conditional offer to the spouse (contingent, for example, on the spouse lacking other employer coverage), with no offer to dependents.
  • 1K. Same conditional spouse offer as 1J, plus an offer to dependents.

The conditional codes 1J and 1K exist so a conditional spouse offer is not treated the same as an unconditional one. Use them when your plan only extends spouse coverage under a condition, such as the spouse not having access to their own employer’s plan.

Line 15: The Employee’s Cheapest Self-Only Cost

Line 15 reports, in dollars and cents, the employee’s required monthly contribution for the lowest-cost self-only plan that meets minimum value. This is not necessarily the plan the employee picked; it is the cheapest qualifying option you made available.

Leave Line 15 blank for any month you did not offer coverage. You can also leave it blank if you used Code 1A on Line 14, because a qualifying offer already certifies affordability.3Internal Revenue Service. Instructions for Forms 1094-C and 1095-C

Line 16: Safe Harbor and Relief Codes

Line 16 explains why no employer shared responsibility payment should apply for that employee that month. Skip the line or pick the wrong code, and you lose the defense even when your coverage genuinely was affordable.

The status-based codes are the straightforward ones:

  • 2A. The employee was not employed on any day of the month.
  • 2B. The employee was not full-time for the month (under 130 hours) and did not enroll in coverage you offered.
  • 2C. The employee enrolled in the minimum essential coverage you offered. Applies whether or not the employee was full-time.
  • 2D. The employee was in a limited non-assessment period, such as a new variable-hour employee’s initial measurement period.

The three affordability safe harbors are the codes that carry the most penalty protection when an employee was offered coverage but did not enroll:3Internal Revenue Service. Instructions for Forms 1094-C and 1095-C

  • 2F — W-2 Safe Harbor. You tested affordability against the employee’s Box 1 W-2 wages. The annual employee contribution cannot exceed 9.96% of those wages. The data is readily available, but this safe harbor can only be applied after year-end.
  • 2G — Federal Poverty Line Safe Harbor. You benchmarked against the FPL for a single individual. For plan years beginning in the first half of 2026, the mainland FPL is $15,650, putting the maximum monthly employee contribution at roughly $129.90.
  • 2H — Rate of Pay Safe Harbor. You used the employee’s lowest hourly rate for the month, multiplied by 130 hours, as a monthly income proxy. Works well for hourly employees and can be applied prospectively.

Use only one Line 16 code per month per employee. If more than one applies, pick the one most favorable to your position. The W-2 safe harbor tends to be easiest for salaried workers; the rate of pay safe harbor gives you a real-time answer for hourly staff without waiting for year-end wages.

Part III: Only If Your Plan Is Self-Insured

Part III applies only to ALEs that sponsor self-insured health plans. If your coverage is fully insured, skip Part III entirely; the insurance carrier handles enrollment reporting separately on Form 1095-B.5Internal Revenue Service. Instructions for Forms 1094-B and 1095-B

If you are self-insured, list every person enrolled in the plan for at least one month during the year, including the employee, spouse, and any covered dependents. Provide each individual’s name and Social Security Number. If no SSN is available, enter the date of birth instead, and make reasonable efforts to obtain the SSN for future filings.

Check the box for each month the individual was actually enrolled. Part III captures all enrolled individuals, not just full-time employees. A part-time employee covered under a self-insured plan gets reported here even though they would not trigger Part II reporting on their own.

Getting the Form to the Employee

You have two ways to satisfy the furnishing requirement. You can still mail the completed 1095-C to the employee the traditional way. Or, under the Paperwork Burden Reduction Act, you can post a notice on your benefits website telling employees they can request a copy.6Internal Revenue Service. Instructions for Forms 1094-C and 1095-C (Draft)

To use the website option, the notice must go up by March 2, 2026, in clear, plain language and a prominent font size. Keep the notice up through at least October 15, 2026. When an employee requests a copy, deliver it by the later of January 31 or 30 days after the request.

Fixing an Error After You File

To correct a wrong Line 14 code, a mistyped SSN, or an incorrect Line 15 dollar amount, check the “CORRECTED” box at the top of the form and resubmit through the same channel you used originally. If the original went through the IRS Affordable Care Act Information Returns system electronically, the correction goes through AIR as well.7Internal Revenue Service. Publication 1220 – Specifications for Electronic Filing of Forms

Timing matters. Corrections filed within 30 days of the filing deadline carry the lowest per-return penalty; the amount rises after 30 days and again after August 1.8Internal Revenue Service. Information Return Penalties File corrections as you find them rather than batching them.