Uploading an e-file requires a TCC for the Air System.  If you do not have a TCC, Transmitter Control Code for the AIR system you will need to apply. The IRS states that it can take up to 45 days.   The TCC that is used for 1099’s is used on the IRS’s FIRE system and cannot be used to upload the 1095’s.

A TCC is specific to a person, so whoever is doing the uploading will need to get their own TCC.  It is recommended to have a 2nd person as a backup.

Link to IRS TCC application: Apply for the Affordable Care Act Application for Transmitter Control Code (TCC) | Internal Revenue Service (irs.gov)

Contact your Auditor/Accountant/IRS if you have any further questions on this new requirement. Failing to file electronically, when required to do so, will likely result in fines.