FTB Publication 3895C: California Instructions for Filing Federal Forms 1094-C and 1095-C (2024)

FTB Publication 3895C is a guidance document issued by the California Franchise Tax Board that walks Applicable Large Employers (ALEs) through how the federal Forms 1094-C and 1095-C tie into California’s own health coverage reporting rules. It isn’t a form you fill out and submit on its own — it’s an instructional booklet that clarifies how information already reported to the IRS under the Affordable Care Act also satisfies (or needs to be adapted for) California’s individual health insurance mandate.

California requires most residents to maintain minimum essential coverage, and employers who offer self-insured health plans or who are otherwise required to report coverage information federally also have a state-level reporting obligation. Publication 3895C exists to help those employers understand exactly how the data from Forms 1094-C (the transmittal form) and 1095-C (the employee statement) should be handled, corrected, or supplemented for California purposes.

Who Needs This Publication

This document is aimed primarily at:

• Applicable Large Employers (generally those with 50 or more full-time employees, including full-time equivalents) who already file Forms 1094-C and 1095-C with the IRS
• Payroll and benefits administrators responsible for state compliance in California
• Tax professionals and preparers who assist employers with combined federal and state health coverage reporting
• HR departments managing self-insured group health plans that cover California residents

If your business doesn’t meet the ALE threshold or doesn’t sponsor a self-insured plan, this publication likely doesn’t apply to you. But if you’re already required to generate 1094-C and 1095-C forms for the IRS, it’s worth reviewing this guidance to confirm you’re not missing a parallel California obligation.

When It’s Used

Employers typically reference Publication 3895C during the annual reporting season, which lines up closely with the federal ACA reporting deadlines. Since California’s individual mandate reporting requirement was built to mirror the federal structure, employers generally prepare their state submissions around the same time they finalize federal filings for the prior tax year. The 2024 version of this publication corresponds to coverage reported for the 2024 tax year, with filings due in the following year.

It’s also useful anytime an employer needs to correct or amend previously submitted coverage information, since the publication outlines how corrections should flow between the federal and state systems.

How to Get and Use the Publication

Publication 3895C is available directly from the Franchise Tax Board’s website as a PDF. It does not contain fillable fields — there’s nothing to type into and save electronically. It’s meant to be read and used as a reference while you complete your actual reporting through the appropriate channels, whether that’s a payroll software system, a third-party reporting service, or manual preparation of the underlying 1094-C and 1095-C data.

Because the guidance references federal forms so heavily, it helps to have copies of the current-year 1094-C and 1095-C forms on hand while reviewing it. Employers unfamiliar with the broader e-filing landscape in California may also benefit from reviewing FTB Publication 1345, which covers the rules for authorized e-file providers and can clarify how electronic submissions are handled more broadly.

Employers juggling multiple state credits and filings alongside health coverage reporting sometimes find it useful to compare processes across different tax credit programs. For instance, businesses evaluating unrelated state-level incentives might look at how documentation works for something like the Green Building Credit claim form or the QETC Capital Tax Credit claim, both of which follow a similarly structured, paper-based process despite being issued by a different state agency.

Because this is a printable-only publication, keep a physical or saved digital copy on file along with your completed 1094-C and 1095-C records in case the FTB requests documentation to verify how your reporting was prepared.