If you’re a small business owner or office admin responsible for health benefits reporting, you’ve likely gotten vague reminders from your insurance carrier about Forms 1094 and 1095 as tax season approaches. Missing a filing deadline can lead to penalties per unfiled form, which adds up fast if you have 10 or more covered employees. This guide walks you through clear decision points, edge cases, and a customizable filing calendar to avoid delays and errors.
Start with one decision: Forms 1094 and 1095: A Filing Calendar for Small Teams
The only first step you need to take is resolving whether you are required to file Forms 1094 and 1095 directly with the IRS, or if your insurance carrier is responsible for filing these forms on your behalf. This is a binary decision that will shape all of your next steps, so resolve it no later than 90 days before the first filing deadline. You can confirm your responsibility by checking your latest health plan service agreement, or reaching out directly to your account manager at your insurance carrier. Note that if you have multiple group health plans for different segments of your team, you may be responsible for filing for one plan while your carrier handles another, so confirm coverage for all active plans during the reporting year. For most fully insured small teams with fewer than 50 full-time equivalent (FTE) employees, carriers will handle all 1094-B and 1095-B filings, as well as distributing 1095-B copies to employees. If you are self-funded, or have 50 or more FTEs (qualifying as an Applicable Large Employer, or ALE), you are responsible for filing the appropriate 1094 transmittal form and 1095 forms directly, plus distributing employee copies.
If/then rules: Forms 1094 and 1095: A Filing Calendar for Small Teams
Use these two paths to map your required tasks based on your first decision:
Path A: Your carrier is responsible for all filings
If you fall into this group, follow these rules:
- By November 15 of the reporting year, confirm with your carrier in writing that they will handle all 1094/1095 filings and employee distribution.
- By December 1 of the reporting year, submit any updates to your employee roster (new hires, terminations, coverage changes, corrected names or Social Security numbers) to your carrier to avoid errors on final forms.
- By January 15 of the filing year, request a sample copy of the 1095 form your carrier will send to employees to review for common errors.
- By March 1 of the filing year, confirm with your carrier that all forms were filed with the IRS and distributed to employees, and save a copy of their confirmation for your records.
You are not required to submit any separate 1094 or 1095 forms to the IRS in this scenario, but you should keep copies of all forms and carrier confirmations for your own records in case of an employee dispute or IRS audit. If an employee reaches out to you with questions about their 1095 form, you can direct them to your carrier’s member services line, but you should also have a copy of the form on file to help resolve basic questions like coverage period details.
Path B: You are responsible for filing directly (ALE or self-funded non-ALE)
If you fall into this group, follow these rules:
- If you choose to file paper forms, the IRS filing deadline is February 28 of the filing year.
- If you choose to file electronically (required if you are submitting 10 or more forms), the IRS filing deadline is March 31 of the filing year.
- You must distribute copies of 1095 forms to employees by March 1 of the filing year, regardless of filing method.
- You must submit a completed 1094 transmittal form (1094-C for ALEs, 1094-B for self-funded non-ALEs) along with all corresponding 1095 forms to the IRS.
You can access free fillable versions of all 1094 and 1095 forms on the IRS website, or use approved third-party payroll software to generate and file forms automatically. If you use a payroll provider, confirm with them whether they include 1094/1095 filing as part of your existing service package, as many small business payroll platforms offer this for an additional fee.
Edge cases: Forms 1094 and 1095: A Filing Calendar for Small Teams
These are the most common unexpected scenarios that can derail small team filing timelines:
- **Mid-year funding type change**: If you switched from fully insured to self-funded (or vice versa) during the reporting year, you will need to coordinate with your old carrier to file forms for the portion of the year they managed coverage, and file your own forms for the portion you managed. Confirm the split of coverage periods with both your carrier and your tax preparer to avoid duplicate or missing filings.
- **Seasonal employees**: If you have seasonal employees who worked fewer than 120 days during the reporting year, you do not need to include these employees on your 1095 forms, but you should keep records of their hours worked to justify the exclusion if the IRS requests it.
- **Replacement form requests**: If an employee requests a replacement copy of their 1095 form after the distribution deadline, you have 30 days from the date of the request to provide the replacement, and you do not need to refile the form with the IRS unless the original form contained an error.
- **Missed deadlines**: The IRS typically waives penalties for first-time filers who can show they made a good faith effort to file on time, as long as you submit the corrected or late filings within 30 days of the missed deadline. For longer delays, you can request a penalty abatement through the IRS website, but you should consult a licensed tax preparer before doing so.
- **Mid-year business merger**: If you merged with another small business during the reporting year, you will need to file separate forms for the period before and after the merger, unless the other business’s health plan was terminated and all employees were moved to your plan on the merger date. Coordinate with the other business’s benefits admin to ensure all employees receive forms covering their full period of coverage during the year.
Illustrative worksheet: Forms 1094 and 1095: A Filing Calendar for Small Teams
Illustrative example: This customizable calendar is for a 22-person fully insured non-ALE team for the 2024 reporting year, with filings due in 2025. Adjust dates and tasks to match your filing responsibility status and reporting year.
| Date Range | Task | Assigned Team Member | Complete? |
|---|---|---|---|
| Nov 1–Nov 15, 2024 | Confirm with health insurance carrier that they will handle 1094-B/1095-B filings and employee distribution; request written confirmation of their responsibility | Office Admin | [ ] |
| Nov 16–Dec 1, 2024 | Audit 2024 employee roster to correct name/SSN errors, note coverage start/end dates for all hires/terminations, submit updates to carrier | HR Lead | [ ] |
| Dec 2–Dec 31, 2024 | Collect and save copies of all 2024 health premium contribution records for your business tax files | Bookkeeper | [ ] |
| Jan 1–Jan 15, 2025 | Request sample 1095-B form from carrier to review for errors; follow up with carrier on any corrections needed | Office Admin | [ ] |
| Jan 16–Feb 28, 2025 | Post a notice in your employee breakroom and internal HR portal letting staff know 1095-B forms will be sent by March 1, and who to contact with questions | HR Lead | [ ] |
| Mar 1–Mar 15, 2025 | Confirm with carrier that all 1095-B forms were mailed to employees and 1094-B/1095-B forms were filed with the IRS; save confirmation to your records | Office Admin | [ ] |
| Mar 16–Dec 31, 2025 | Store all filing confirmations and 1094/1095 copies for a minimum of 3 years for tax audit purposes | Bookkeeper | [ ] |
For teams filing directly (Path B), add these tasks to the calendar:
* Jan 16–Feb 15, 2025: Complete draft 1094 and 1095 forms, review for errors with your tax preparer
* Feb 16–Feb 28, 2025: File paper forms with the IRS if filing via mail, distribute 1095 copies to employees
* Mar 1–Mar 31, 2025: File electronic forms with the IRS if filing digitally, send follow-up reminder to employees who have not received their 1095 forms
Bottom line: Forms 1094 and 1095: A Filing Calendar for Small Teams
The most common source of 1094/1095 filing delays for small teams is miscommunication about who is responsible for filing, so clarifying that responsibility at least 3 months before the first deadline will eliminate most errors. Even if your carrier handles all filings, you are still responsible for ensuring your employee roster information is accurate, so setting regular calendar reminders to audit that roster will prevent costly correction requests later.
This content is for educational purposes only and does not constitute insurance, tax, or legal advice. Always verify all filing requirements with your plan documents, the IRS website, and a licensed broker or tax preparer before submitting forms.
