Annual Reporting Reminder: Forms 1095-C and 5500 Due for 100+ Employee Groups
For the 2025 plan year, applicable large employers and other reporting entities should take note of upcoming federal reporting deadlines related to Form 1095-C and Form 5500 filings. These requirements remain an important part of Affordable Care Act (“ACA”) compliance and employee benefit plan reporting.
This article highlights key deadlines, filing requirements, and best practices to ensure employers stay on track and meet federal obligations with confidence.
IRS Reporting Deadline for 1095-C
The following overview outlines key deadlines and requirements employers should consider.
Deadline for Employee Copy and Filing
Employers must furnish Form 1095-C to eligible employees and file corresponding information returns with the Internal Revenue Service each year. These forms report information regarding health coverage offered to full-time employees and support the administration of employer shared responsibility provisions and premium tax credits.
For the 2025 reporting cycle:
Employers must furnish Forms 1095-C to covered individuals by March 2, 2026.
Employers filing electronically must submit Forms 1094-C and 1095-C by March 31, 2026.
Because of these timelines, employers are encouraged to review employee records early, confirm data accuracy, and coordinate with payroll and benefits vendors to ensure consistent reporting.
IRS Form 1095-C and 5500 Reporting Requirements
Form 1095-C Reporting Requirements
Businesses with 50 or more full-time employees must report information about the health insurance coverage they offer to employees.
To meet compliance requirements, employers must:
Report health coverage details to the IRS: Employers must provide information about whether health insurance was offered to full-time employees, the cost of coverage, and the months coverage was available.
Provide Form 1095-C to employees: A copy of the form must be given to each full-time employee annually so they can verify their health coverage and determine eligibility for premium tax credits.
File Form 1094-C with the IRS: This form acts as a summary transmittal that accompanies all submitted Form 1095-C reports.
Meet annual filing deadlines: Employers must submit forms to employees and file them with the IRS by the required deadlines each year.
File electronically if required: Employers filing 10 or more returns must submit them electronically.
Penalty for Filing Late
Failure to comply may result in penalties from the IRS for incorrect, incomplete, or late reporting. These penalties apply when employers fail to submit required forms on time or do not provide accurate information to employees.
Penalty for not filing correct information returns: Employers who fail to file required reports may face a penalty for each incorrect or late return. The penalty is generally $270 per return, with total annual penalties capped at $3,275,500.
Penalty for not providing employee statements: Employers must also give employees accurate coverage statements. Failure to provide correct or timely statements can result in a similar penalty of $270 per statement, with the same annual maximum limit.
Higher penalties for intentional disregard: If an employer intentionally ignores reporting requirements, the penalties may be significantly higher.
In some cases, penalties may be reduced or waived if an employer can show a valid reason for the failure and demonstrate good-faith efforts to comply with reporting rules.
IRS Reporting Deadline for 5500
Employers sponsoring employee benefit and retirement plans should also be aware of the annual filing requirements related to Form 5500. The Form 5500 series was developed jointly by the Internal Revenue Service, the Department of Labor, and the Pension Benefit Guaranty Corporation to satisfy annual reporting obligations for employee benefit plans under federal law.
The following overview highlights key considerations for Form 5500 reporting.
Deadline for Employee Copy and Filing
Form 5500 must be filed on the last day of the seventh month after the plan year ends. For example, plans that operate on a calendar-year basis typically must file by July 31 of the following year.
If additional time is required, plan sponsors can request an extension by filing Form 5558. Beginning January 1, 2025, Form 5558 may be submitted electronically through the EFAST2 system or filed on paper with federal authorities.
Reporting Requirements
Form 5500 reporting requirements can vary depending on the type of benefit plan, the number of participants, and how the plan is structured.
Electronic Filing for One-Participant and Foreign Plans: One-participant plans (such as owner-only retirement plans) and certain foreign plans may file Form 5500-EZ electronically using the Department of Labor’s EFAST2 filing system. They may also choose to file Form 5500-EZ on paper with the IRS.
Requirements for Retroactively Adopted Plans: If an employer adopts a benefit plan retroactively, a Form 5500 filing may not be required for the earlier plan year, and the first required filing applies to the following plan year.
The plan sponsor must report the retroactive adoption on the Form 5500 filed with the IRS, and certain plans, such as defined benefit plans, may require additional supporting schedules for prior plan years.
Extension Requests and Filing Responsibilities: Plan sponsors that need additional time to file may request an extension using Form 5558.
Because requirements can depend on plan structure and timing, employers should carefully review filing obligations each year.
Penalty for Filing Late
Failure to file Form 5500 or related returns may result in federal penalties. In general:
Failure to file Form 5500 series returns may result in penalties of $250 per day, up to a maximum of $150,000.
Failure to file Form 8955-SSA (participant reporting) may result in daily penalties based on the number of affected participants, subject to a maximum limit.
Penalty relief programs may be available in certain situations, such as when employers demonstrate reasonable cause or use IRS correction programs for late filings.
Need Help Meeting These Deadlines?
At Schulman Insurance Brokerage, we help employers understand benefit plan rules, manage reporting requirements, and stay compliant. Our team reviews plan structures, coordinates with service providers, and provides practical, tailored solutions.
If you need support with Forms 1095-C or 5500, or want a review of your current processes, now is the time to get guidance before deadlines arrive.