Filing Requirements for IRS Forms 1094 and 1095

The IRS has released final Forms 1094 and 1095, which will be used to enforce the ACA employer mandate penalties and the individual mandate and tax credit eligibility rules. These forms must first be filed by employers and insurers in early 2016, for the 2015 calendar year. Filing is optional in 2015 for the 2014 calendar year. While we do not recommend voluntary filing, we do recommend employers review the forms and the instructions so they are aware of what filing in 2016 will involve because they need to be gathering the information to report now.

Author: Erwin Kratz

Mr. Kratz practices in the areas of ERISA and employee benefits law, focusing on tax and regulatory matters relating to qualified and nonqualified deferred compensation and welfare benefits.

2 thoughts on “Filing Requirements for IRS Forms 1094 and 1095”

  1. And More IRS Q&As on Reporting of Offers of Health Insurance Coverage by Employers (Section 6056), which is first required in early 2016 with respect to calendar year 2015 are available at
    Topics addressed:
    * Basics of Employer Reporting
    * Who is Required to Report
    * Methods of Reporting
    * How and When to Report the Required Information

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