ACA 1094-C and 1095-C Filing for Applicable Large Employers

File your full ACA reporting package — Form 1094-C transmittal plus 1095-C employee statements — directly to the IRS through AIR. Built for ALEs filing for the first time and for HR teams replacing a commodity e-filer with something they can defend in an audit.

Start Your ACA Filing

What We File

The complete ACA employer reporting package, transmitted to the IRS through the Affordable Care Act Information Returns (AIR) system.

Form 1094-C — Transmittal

The employer-level transmittal that tells the IRS who you are, how many 1095-Cs you are sending, and your aggregated ALE status. We populate Parts I–IV from your roster and coverage data, no manual line-by-line entry.

Form 1095-C — Employee Statements

One return per full-time employee covering offer of coverage (Line 14), employee share of the lowest-cost premium (Line 15), and Safe Harbor codes (Line 16). We generate every 1095-C from your roster and validate code combinations before transmission.

Direct AIR Transmission

Filed through the IRS Affordable Care Act Information Returns system. Thomas Ledger holds a registered Transmitter Control Code (TCC) and is IRS-accepted in AATS for TY2025 (Software ID 25A0024798). No portal logins, no manual upload.

Line 14 / 16 Code Review

The substantive part of ACA filing is the code selection on Lines 14 and 16 — and it is where commodity e-filers leave you exposed. Our workflow validates code combinations against IRS rules before submission and flags anything that would draw a Letter 226J.

Safe Harbor Logic

Federal Poverty Line, Rate of Pay, and W-2 Safe Harbor calculations applied per employee, per month. We track which Safe Harbor you elected and apply the matching Line 16 code consistently across the year.

Employee Copy Delivery

Print and mail 1095-C copies to your employees, or deliver electronically with the IRS-required consent capture. Both methods satisfy the January 31 furnishing deadline.

Who This Is For

ACA reporting under §6055 / §6056 applies to Applicable Large Employers — employers with 50 or more full-time and full-time-equivalent employees in the prior calendar year. Forms 1094-C and 1095-C are how ALEs report offers of health coverage to the IRS.

If any of these describe you, you have an ACA filing obligation and Thomas Ledger is built for your case:

If your headcount is under 50 FTE, you generally do not have an ACA reporting obligation. See ACA for ALE Employers for the threshold rules, including the controlled-group aggregation that catches surprisingly many employers.

How It Works

  1. Step 1: Tell us your FTE band

    At signup, you self-report your full-time employee count — the same number you use to determine ALE status. That sets your annual filing band. No counting, no per-form metering.

  2. Step 2: Upload your employee and coverage data

    Provide your roster, offer-of-coverage details, monthly cost share, and any Safe Harbor elections. We accept CSV, XLSX, and direct extracts from common payroll and benefits systems.

  3. Step 3: Review codes and Safe Harbor logic

    The platform generates Line 14 and Line 16 codes for every employee, every month. You review the exceptions — anything ambiguous, any month an employee was in a limited non-assessment period — before approving.

  4. Step 4: File through AIR

    One click transmits 1094-C and all 1095-Cs to the IRS through AIR. You receive the IRS acknowledgment and a downloadable archive of every form filed under your TCC.

Annual Pricing — Banded by Full-Time Employee Count

ACA filing is priced per tax year, flat, with the band keyed off the same FTE count you use to determine ALE status. You self-report at signup, we verify once at filing, and we true up once if you crossed a band. No per-form charges, no monthly metering.

ACA Filer

$650/tax year

Up to 100 full-time employees

  • Full 1094-C + 1095-C filing
  • Direct AIR transmission
  • Line 14 / 16 code generation
  • Single Safe Harbor support
  • $150 off that year's 1099 filing
Most Popular

ACA Filer Pro

$1,500/tax year

101–250 full-time employees

  • Everything in Filer
  • Multi-state ALE support
  • Self-insured 1095-C Part III
  • TIN matching included
  • That year's 1099 filing included free

ACA Filer Pro

$2,900/tax year

251–500 full-time employees

  • Everything in Filer Pro (101–250)
  • Multiple Safe Harbor strategies
  • Aggregated ALE (controlled group) filing
  • That year's 1099 filing included free

ACA Filer Elite

Private quote

500+ FTEs / federal contractors

  • Combined 1099 + ACA engagement
  • Multi-year catch-up supported
  • Audit and notice consultation hours
  • Single-vendor clearance trail

View full pricing and end-to-end add-ons →

The Penalty Math

ACA penalties under §4980H dwarf the cost of filing — and they are assessed per affected full-time employee, not per form. The IRS published amounts for 2026:

The arithmetic is unforgiving — a 120-employee ALE that misfiles a Safe Harbor and triggers Penalty B against 8 employees is looking at $40,080 in exposure. The annual filing fee is rounding error against that number; the value of Thomas Ledger is that the Line 14 / 16 logic and Safe Harbor tracking are validated before transmission, not after the IRS sends a Letter 226J.

Ready to File Your ACA Returns?

Already a Thomas Ledger 1099 customer? ACA filing adds to your existing account — no separate signup. New here? Create your account and start with the FTE band that matches your roster.

Create Your Account

Frequently Asked Questions

Do you file both 1094-C and 1095-C?

Yes. A complete ACA filing includes one 1094-C transmittal plus one 1095-C per full-time employee. Thomas Ledger generates and transmits both in a single AIR submission. See 1094-C vs 1095-C for the difference between the two forms.

Is Thomas Ledger IRS-approved for ACA filing?

Yes. Thomas Ledger is IRS-accepted in AATS (the IRS Assurance Testing System) for TY2025 with Software ID 25A0024798, and holds a registered Transmitter Control Code for AIR transmission. AATS acceptance is the IRS's formal sign-off that a software vendor can file 1094-C / 1095-C in production.

What is the ACA filing deadline?

For TY2025 forms filed in 2026: employee copies of 1095-C are due by March 3, 2026 (the standard January 31 deadline with the 30-day automatic extension). Electronic filing with the IRS is due by March 31, 2026. Thomas Ledger files electronically — paper filing is only allowed for employers with under 10 returns total across all information return types.

Do you support self-insured employers?

Yes. Self-insured ALEs report covered individuals on Part III of Form 1095-C — dependent names, SSNs, and months covered. The ACA Filer Pro tier and above include Part III handling. Fully-insured ALEs skip Part III; their insurance carrier files Form 1095-B separately.

What if I'm in a controlled group with multiple EINs?

Aggregated ALE filing is supported on the Filer Pro (251–500) and ACA Filer Elite tiers. You file one 1094-C per EIN in the controlled group, with Part IV listing the other member EINs and their FT employee counts. We generate the cross-references so the filings line up.

Can I file ACA without also filing 1099s?

Yes. ACA and 1099 are separate products with separate pricing. The bundle benefit — your tax year's 1099 filing included free — kicks in at ACA Filer Pro (101+ FTEs); below that tier, the two products are billed independently. See the pricing page for the full layout.

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