IRS Forms 1095-B and 1094-B: ACA Compliance Guide for HR

Executive overview

Forms 1095-B and 1094-B are IRS documents used to demonstrate compliance with the Affordable Care Act's health coverage requirements. The 1095-B proves minimum essential coverage for individuals, while the 1094-B is the transmittal cover sheet that accompanies it when filing with the IRS. Filing responsibility falls on insurance carriers for fully insured plans and on small self-insured employers (fewer than 50 FTEs) — larger employers use different forms (1095-C/1094-C). Missing the deadlines risks non-compliance, so understanding which forms apply to your organization is essential.

What the forms contain

• 1095-B records the insured individual's name, coverage type, and coverage start and end dates.
• 1094-B acts as a summary transmittal, consolidating all 1095-B forms submitted by the organization.
• Together they serve as proof that employees met ACA coverage requirements for the tax year.

Who must file

• Health insurance issuers and carriers file for fully insured plans.
• Self-insured employers with fewer than 50 full-time equivalent employees file 1095-B and 1094-B.
• Employers with 50 or more FTEs file 1095-C and 1094-C instead — different forms entirely.
• Choosing the wrong form based on plan type or employer size is a common compliance mistake.

Filing deadlines for the 2024 tax year

• Employee copies of 1095-B must be distributed by March 3, 2025.
• Electronic filing with the IRS is due by March 31, 2025.
• Paper filing deadline is February 28, 2025.
• All-in-one HR platforms can automate electronic submission and employee mailing to meet these dates.