The Affordable Care Act (ACA) requires certain employers to file Forms 1095-C and 1094-C every year with the IRS. These forms are critical for demonstrating that you offered health coverage to your full-time employees, and missing the deadline can lead to costly penalties. If you’ve found yourself in this situation—maybe due to system issues, confusion about the rules, or simply being short-staffed—you’re not alone.
The good news is that late filing doesn’t automatically mean you’re doomed. There are still steps you can take to mitigate penalties, correct the issue, and get back on track with compliance. This guide will walk you through exactly what to do if you missed the 1095-C or 1094-C filing deadline.
Why These ACA Forms Matter
Forms 1095-C and 1094-C are required under the employer mandate provision of the ACA. The IRS uses these forms to determine whether you, as an Applicable Large Employer (ALE), offered minimum essential coverage that was affordable and met minimum value standards to at least 95% of your full-time workforce.
Form 1095-C is issued to employees and reports details about the coverage offered to them. Form 1094-C is the transmittal form that summarizes this data for the IRS.
Failing to submit these forms on time doesn’t just result in a slap on the wrist. It can trigger automatic penalties—even if you were otherwise in compliance with your coverage obligations.
IRS Deadlines for 1095-C and 1094-C
Each year, the IRS sets firm deadlines for filing the ACA. Typically, employers must:
- Furnish Form 1095-C to employees by early March
- File Forms 1095-C and 1094-C with the IRS by the end of February if filing by paper, or by the end of March if filing electronically
Missing these deadlines even by a few days can result in per-form penalties. With hundreds of employees, those fines can quickly add up to tens of thousands of dollars or more.
Common Reasons Employers Miss the Deadline
Late ACA filings happen for a variety of reasons. Some employers misunderstand whether they’re considered an ALE under the 50-employee threshold. Others face delays due to internal staffing shortages, payroll vendor problems, or HR system incompatibilities.
Sometimes, changes in organizational structure—like mergers or acquisitions—can cause confusion over reporting responsibilities. Even well-intentioned businesses can struggle with last-minute data issues that make on-time filing impossible.
Regardless of the cause, it’s important to act quickly if you’ve missed the deadline.
What Happens If You File Late?
If you file ACA forms after the official IRS deadline, the agency will assess penalties under IRC Sections 6721 and 6722. The amount depends on how late the forms are filed and whether the mistake was intentional.
For example, if you file within 30 days of the deadline, the penalty per return may be around $60. However, if you wait more than 6 months, that amount can jump to $310 per return or more. These penalties apply separately for failing to file with the IRS and for failing to furnish correct forms to employees.
If you’ve already received a letter or penalty notice from the IRS, such as Notice 972CG or a CP220J, that means action is urgently required.
How to Respond If You’re Late
The first step is not to panic. Late filing is fixable, especially if you act fast. Here’s a roadmap to follow:
- File the ACA forms immediately. Even if the deadline has passed, getting the correct forms submitted quickly can help limit your penalty exposure.
- Review for accuracy. Double-check the forms for mistakes before submission. Incorrect or incomplete information can trigger additional penalties.
- Include a reasonable cause explanation, if appropriate. If the delay was due to unforeseen circumstances (e.g., natural disaster, vendor failure, illness), you can request a waiver or reduction of penalties by submitting a reasonable cause letter with your filing.
- Consult a compliance expert. Navigating late filings is tricky, and partnering with a service provider like 1095EZ Online can ensure you’re handling it correctly from both a filing and documentation standpoint.
Avoiding Compounding Mistakes
Filing late is one issue—filing late and inaccurately is another. The IRS won’t just fine you for lateness; they’ll also assess penalties for bad data. Common errors include using the wrong codes, submitting forms with missing EINs or SSNs, or failing to check key boxes on the 1094-C.
Also, don’t assume that just because you missed the deadline, you should wait until next year. The longer you delay, the greater the penalties, and the harder it becomes to justify your inaction.
Reasonable Cause and Penalty Relief
In many cases, especially for first-time offenders, the IRS may waive or reduce penalties if you can demonstrate reasonable cause. That means showing that you exercised ordinary business care and prudence but still failed to comply due to circumstances beyond your control.
To make a strong case, your explanation should include specific dates, supporting documentation (e.g., emails from a failed vendor), and evidence that you corrected the problem as quickly as possible.
When to Consider Filing Corrections
If you already submitted your forms but later discovered errors, you’re required to file corrected versions. This could include changes to employee information, plan codes, or covered dependents. The good news is that correcting mistakes voluntarily can reduce your penalty risk and show the IRS that you're making a good-faith effort to comply.
How 1095EZ Online Can Help
When you're dealing with late ACA filings, the stakes are high. That’s why many businesses turn to 1095EZ Online. Their platform is specifically designed to simplify ACA compliance—even if you're behind schedule. Their expert team handles everything from gathering data and validating forms to submitting filings with the IRS and employees.
Even if you're already late, 1095EZ Online can work quickly to help you file correctly, respond to notices, and avoid further penalties. Their experience with penalty relief and reasonable cause documentation can also be a huge asset.
Planning Ahead for Next Year
One of the best ways to avoid a late filing crisis next year is to start planning now. Establish clear internal deadlines, ensure you know whether you’re an ALE, and consider using a trusted service like 1095EZ Online for your future ACA reporting.
Get your employee data organized early, confirm your reporting responsibilities, and don’t wait until the last minute. When you take ACA compliance seriously year-round, you dramatically reduce your risk of penalties and paperwork headaches.
Don’t Ignore the Problem
Missing the ACA filing deadline can feel overwhelming, especially if you’re a busy employer with limited resources. But ignoring the problem won’t make it go away. The longer you wait, the more complex and costly it becomes.
Whether you’ve missed the 1095-C deadline, the 1094-C deadline, or both, your next step should be to file as soon as possible and consult experts who know how to minimize the damage. With the right guidance, you can get back in compliance and prevent future issues before they begin.
1095EZ Online is here to help—on time, every time. Get started today!