Some Draft Forms for 2020 ACA Reporting Released

The Internal Revenue Service (IRS) released draft 2020 forms for reporting under Internal Revenue Code (Code) Section 6056. 2020 draft Forms 1094-C and 1095-C are draft versions of forms that will be used by applicable large employers (ALEs) to report under Section 6056, as well as for combined Section 6055 and 6056 reporting by ALEs who sponsor self-insured plans. Draft instructions for Forms 1094-C and 1095-C have not yet been released.


  • Draft forms for 2020 reporting under Section 6056 are now available.
  • Draft instructions and draft forms for reporting under Section 6055 have not been released at this time.
  • Draft Form 1095-C includes additional codes in Code Series 1 related to Individual Coverage Health Reimbursement Arrangments (ICHRAs).
  • Draft Form 1095-C also includes a new section to enter the zip code used to determine affordability for an ICHRA.

Action Steps for Employers

Employers should become familiar with these forms for reporting for the 2020 calendar year. However, these forms are draft versions only, and should not be filed with the IRS or relied upon for filing.

In addition, employers should monitor future developments for the release of 2020 draft Forms 1094-B and 1095-B, along with related draft instructions for these forms.

If you have questions related to this update, please contact your North Risk Partners advisor. Don’t have an advisor? No problem. We’ll help you find one.

This regulatory update is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice.