By - May 4, 2020

California Individual Mandate: Update on Reporting Requirements

CA individual mandate reporting

California Issues New Guidance on 1094-C and 1095-C Reporting

The California Individual Mandate law went into effect on January 1, 2020. Not only does it require residents to have healthcare, but it also includes a provision requiring employers to file returns electronically for California residents.

Employers Only Filing for Self-Insured Enrollees

Unlike the State of New Jersey and District of Columbia, the State of California only requires employers to submit forms for any employee and their dependents who are enrolled in self-insured health coverage. They do not need to see offers of coverage for non-enrolled employees or those enrolled in fully-insured plans.

While this lessens the number of forms to report, this does mean that employers will need to specifically exclude forms when they submit their data and it will be a smaller file than what is currently provided to the IRS. Similarly, non-California residents should be excluded from the filing.


Forms must be furnished to employees by January 31st of each year. If the federal government provides an extension, it would also apply to California. The forms must then be electronically submitted to the State of California by May 31st of each year. Failure to submit forms will be penalized at $50 per enrolled individual.

Electronic Submissions Encouraged

Employers with over 250 forms are required to submit electronically through the State’s FTB File Exchange system. While they intend to use the same XML format used by the IRS for receiving 1094-C and 1095-C information, the contents of the file will be different with California-specific reporting codes and only enrolled self-insured employees.

For more information about Tango Health’s state mandate reporting service, or for a complete guide on all the states with an employer-reporting requirement, please visit https://www.tangohealth.com/complete-guide-state-healthcare-mandates/

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