IRS Issued Notice 2016-4: Extending the Due Dates for Forms 1094-C and 1095-C for 2015

1094-c and 1095-c

Great news for Applicable Large Employers (ALE) and self-insuring employers, who are required to report under Section 6055 and 6056 of the Internal Revenue Code.  Per the IRS Notice 2016-4, they extended the deadlines for the 2015 Affordable Care Act (ACA) information requirements to complete the 2015 Forms 1094-C and 1095-C.  Coverage providers also have additional time to file and distribute the B series forms for 2015 Calendar Year only.

Under the ACA, Applicable Large Employers must file the 2015 Forms 1094-C and 1095-C with the IRS, and furnish copies of the 1095-Cs to full-time employees (and to covered part-time employees, if the employer’s plan is self-funded).  There are no exceptions to the filing requirement.  Many ALEs have found compliance with this mandate challenging, therefore, we welcome the extension from the IRS to allow employers a couple more months to prepare.


  • Form Distribution to Individuals (Forms 1095-B and 1095-C):
    • Extended from February 1, 2016 to March 31, 0216.
  • IRS Form Filing (1094-B, 1095-B, 1094-C, and 1095-C):
    • Extended from February 29, 2015 to May 31, 0216 (paper filing)
    • Extended from March 31, 2016 to June 30, 2016 (electronic filing)

IMPORTANT NOTE: The extensions for the ACA information reporting requirements apply for calendar year 2015 only and have no effect of the requirements for other years or on the effective dates or application of the ACA “Pay or Play” provisions.  Applicable Large Employers or other coverage providers that do not comply with these extended due dates will be subject to penalties.


2015 Required Forms:

Form 1094-B

Form 1095-B

Form 1094-C

Form 1095-C

2015 Form Instructions:

1094-B Instructions

1095-B Instructions

1094-C Instructions

1095-C Instructions

General Penalty:

HR 1295


6055 IRS Q&A

6056 IRS Q&A

1094-C & 1095-C FAQs


If you would like to further discuss the ACA Employer Reporting Requirements, penalties, and how it affects your company, please contact MNJ Insurance Solutions at (714) 716-4303.


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