IRS Releases Final 1094/1095 B and C Forms

The IRS released final Forms 1094/1095-B and Forms 1094/1095-C and related instructions for the 2020 tax year. The new forms add information related to Individual Coverage HRAs (ICHRAs), but make few additional changes.



  • 1095-B: A new code (G) must be added to identify an ICHRA.
  • 1095-C: Employers may rely on proposed regulations issued by the IRS on 9/30/2019 that clarify how ICHRAs may satisfy the employer shared responsibility provisions (Sec. 4980H) of the Affordable Care Act (ACA).
  • 1095-C: Adds new codes for reporting offers of ICHRAs.
  • 1095-C: Adds new lines for reporting required ICHRA information.

Other Changes

  • 1095-C: “Plan Start Month” is a required field for 2020 forms.

Due Dates and Relief (see our related blog)

  • Due date for furnishing statements to individuals extended to March 2, 2021.
  • Relief provided (or extended) for failure to provide statements to certain employees and for good faith reporting and furnishing.

Indexed Penalties

  • Penalties for each form adjusted to $280 per return with a $3,392,000 calendar-year maximum.

2020 (Plan Year) Forms and Instructions

B-Form Instructions



C-Form Instructions



For more information on these forms and the employer shared responsibility provisions, consult your ComplianceDashboard.

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