Build ACA 1094-C/1095-C E-File (IRS AIR XML)
Skill: Convert employee coverage offers into an ACA Information Return for AIR
Region: United States Category: Health Care EDI Does: Takes an Applicable Large Employer's (ALE) health-coverage-offer data and assembles the IRS AIR (Affordable Care Act Information Returns) XML — the Form 1094-C transmittal and per-employee Form 1095-C statements employers file under IRC §6056 to report offers of minimum-essential coverage. System: IRS AIR (ACA Information Returns) — Pub. 5165 (composition) / Pub. 5258 (submission)
AIR is its own XML channel (separate from 94x MeF and from FIRE/IRIS). A submission is two XML files: a Manifest (transmitter + submission metadata) and a Form Data File (the 1094-C + 1095-C records). Filing requires an AIR TCC (ACA-specific) and passing AATS testing. Element names below follow the AIR schemas; map onto the current tax-year version (e.g. the 1094-C/1095-C v-release for the year).
When filing applies
- An ALE — an employer with 50+ full-time + full-time-equivalent employees in the prior year — must file a 1095-C for each full-time employee and a 1094-C transmittal.
- Electronic filing is required at 10+ returns (aggregated across return types). The IRS no longer accepts ACA paper at scale.
- Deadlines (typical): furnish 1095-C to employees by early March; e-file with the IRS via AIR by March 31. Confirm the year's exact dates.
Input data required
| Group | Fields |
|---|---|
| Transmitter (Manifest) | TCC, software ID, payment year, transmission type (O original / C correction / R replacement), record counts, checksum |
| ALE member (1094-C) | EIN, name, address, contact; Authoritative Transmittal flag; full-time & total employee counts by month; Aggregated ALE Group membership; certifications of eligibility |
| Employee (1095-C) | name, SSN, address |
| Coverage (1095-C Part II) | Line 14 offer-of-coverage code, Line 15 employee required contribution (lowest-cost self-only), Line 16 safe-harbor/relief code — monthly or "all 12 months" |
| Self-insured (Part III) | covered individuals + months (if the plan is self-insured) |
Structure (AIR → two XML files)
Manifest XML
TransmitterControlCode (TCC), TaxYr, TransmissionTypeCd (O/C/R)
TotalPayeeRecordCnt, TotalPayeeCnt, ChecksumAugmentationNum, AttachmentByteSizeNum
Form Data File XML
Form1094CUpstreamDetail (one Authoritative Transmittal per ALE EIN)
employer identity, monthly FT/total employee counts, ALE-group members, certifications
Form1095CUpstreamDetail (one per employee)
employee identity (name/SSN/address)
EmployeeOfferAndCoverageGrp (Line 14 / 15 / 16 — annual or monthly)
CoveredIndividualGrp (Part III — self-insured only)
Key code sets
| Field | Examples |
|---|---|
| Line 14 (offer code, series 1) | 1A Qualifying Offer; 1E MEC offering MV to employee + spouse + dependents; 1H no offer |
| Line 16 (safe harbor / relief, series 2) | 2A not employed; 2C enrolled in coverage; 2F/2G/2H W-2 / FPL / rate-of-pay affordability safe harbors |
| Line 15 | dollar amount — required when Line 14 indicates an offer requiring a contribution figure |
Data rules
- Exactly one 1094-C per ALE EIN is the Authoritative Transmittal (carries the full-year counts and certifications); additional 1094-Cs (if splitting batches) are non-authoritative.
- Line 14/15/16 must be internally consistent per month: e.g.
1AQualifying Offer implies affordability and generally pairs with a blank/2-series consistent with enrollment;2C(enrolled) overrides most other Line 16 codes. Line 15 contribution is required for codes that signal an offer with a cost. - Monthly vs all-12: use the "All 12 Months" field when every month is identical; otherwise populate each month.
- Self-insured employers complete Part III (covered individuals + the months each was covered); fully-insured employers leave Part III to the insurer's 1095-B.
- Manifest counts/checksum must match the Form Data File exactly, or AIR rejects the transmission; corrections (
C) reference the original Receipt ID and record.
Worked example (one full-time employee, covered all year — outline)
Manifest: TCC=AB12C, TaxYr=2025, TransmissionTypeCd=O, TotalPayeeRecordCnt=1
1094-C (Authoritative=Yes): EIN=123456789, ACME LLC; FT count 40/total 55 each month;
Certification: Qualifying Offer Method
1095-C: Jane Doe, SSN 123-45-6789
Offer/Coverage — All 12 Months: Line14=1E, Line15=120.00, Line16=2C
(Offered MV coverage to employee+spouse+dependents; employee enrolled; $120/mo cost)
Emitted as the Manifest + Form Data XML pair and transmitted through the AIR channel.
Validation checklist
- Filer is an ALE (50+ FT/FTE prior year); 1095-C for each full-time employee + a 1094-C transmittal
- AIR TCC obtained and AATS testing passed; current-year 1094-C/1095-C AIR schemas used
- Exactly one Authoritative Transmittal 1094-C per EIN; monthly FT/total counts populated
- Line 14 (offer) / Line 15 (contribution) / Line 16 (safe harbor) consistent per month; All-12 vs monthly correct
- Self-insured plans complete Part III covered individuals; fully-insured leave it blank
- Manifest record counts + checksum match the Form Data File; transmission type (O/C/R) correct
- Employee SSNs valid (TIN solicitation documented); ALE Aggregated Group members listed if applicable
- Furnish-to-employee and e-file (AIR, ~Mar 31) deadlines met
Last updated: 2026-05-31 — AIR schemas and code interpretations change yearly; confirm element names, the current 1094-C/1095-C AIR schema version, Line 14/15/16 code rules, ALE thresholds, and deadlines against current IRS AIR / Pub. 5165 guidance before use.