From: Health Care Reform
For Affordable Care Act (ACA) reporting, is an employer required to file Forms 1094 or 1095 if it has less than 50 full time equivalent (FTE) employees?
Only if the employer offers a self-funded plan. In that case the employer would complete forms 1094-B and 1095-B. Otherwise, only applicable large employers (ALEs) are required to complete forms 1094-C and 1095-C. ALEs are those who had an average of 50 full-time employees (including FTEs) in the previous calendar year.