Final Forms for ACA Reporting Released


On Dec. 9, 2019, the Internal Revenue Service (IRS) released final 2019 forms and instructions for reporting under Internal Revenue Code (Code) Sections 6055 and 6056.

  • 2019 Forms 1094-C and 1095-C (and instructions) will be used by applicable large employers (ALEs) to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans.
  • 2019 Forms 1094-B and 1095-B (and instructions) will be used by entities reporting under Section 6055, including self-insured plan sponsors that are not ALEs.

The 2019 forms and instructions are substantially similar to the 2018 versions. Note that Section 6055 reporting is still required, despite the fact that the individual mandate penalty has been reduced to $0, although transition relief from penalties is available in certain circumstances.


Employers should become familiar with these forms for reporting for the 2019 calendar year. Individual statements must be furnished by March 2, 2020, and IRS returns must be filed by Feb. 28, 2020 (March 31, 2020, if filed electronically).

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