IRS Releases Draft 1094/1095 Forms

IRS Releases Draft 1094/1095 Forms

IRS Releases Draft 1094/1095 Forms and Instructions for Reporting Health Coverage for 2019

On November 13, 2019, the IRS released draft Forms 1094 and 1095 with their accompanying instructions, which are used by applicable large employers and small employers with self-insured coverage to report certain health coverage information for the 2019 calendar year. Despite rumblings of potential changes to these forms with the removal of the individual shared responsibility penalty for 2019, these draft forms and instructions do not reflect any substantive changes.

The reporting deadlines for these forms are approaching quickly:

  • Forms 1095-B and 1095-C must be furnished to individuals no later than January 31, 2020
  • Forms 1094-B and 1095-B or Forms 1094-C and 1095-C must be filed with the IRS no later than February 28, 2020, if filing by paper, or March 31, 2020, if filing electronically.

The IRS has been actively enforcing Code Section 6721 and 6722 penalties for employers who fail to comply with these reporting requirements through Letters 5699 and 5005-A and Notice 972-CG. These penalties are generally $270 per form for filings that occur or should have occurred in 2020 for the 2019 tax year. Further, there is no guarantee that the IRS will offer any deadline extensions or good faith transition relief, as they have with past reporting years. Accordingly, it is vital that employers subject to these reporting requirements ensure they have a reporting solution in place now to avoid costly penalties.

The draft forms and instructions are available below, and we will keep you apprised once these forms and instructions are available in their final formats. If you have any questions about the reporting requirements or IRS penalty enforcement efforts, ETC Companies has resources to help. Please contact us at for more information.


Draft 2019 Form 1094-B:–dft.pdf

Draft 2019 Form 1095-B:–dft.pdf

Draft 2019 Instructions for Forms 1094-B and 1095-B:–dft.pdf


Draft 2019 Form 1094-C:–dft.pdf

Draft 2019 Form 1095-C:–dft.pdf

Draft 2019 Instructions for Forms 1094-C and 1095-C:–dft.pdf

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