1095-C Review and Approval Checklist

Give the reviewer a cover sheet with the employer, calendar year, batch ID, draft version, expected count, and preparation date. State whether the packet is a complete employer population, a partial batch, or a correction set. Identify any material changes since the prior draft.

Attach the reconciled population, open exception log, and source references. Ask the reviewer to distinguish a missing document from a known reporting question. Both can block an informed approval, but they need different owners.

Assign review responsibilities by competence. Payroll can confirm employment facts; benefits can confirm offer and enrollment records; the designated tax reviewer can assess difficult reporting treatments. The final approver should know which reviews actually occurred.

Reconcile the prepared person-employer count to the reviewed population. Investigate missing records, unexpected additions, and duplicate relationships before spending time on individual codes. A technically valid form is still a problem if the required person's record never entered the batch.

Compare the employer's legal name, EIN reference, and address across the approved entity register, Form 1095-C drafts, and the associated employer summary. The 2025 Form 1094-C is the employer-level transmittal and summary form. Have its responsible reviewer check the summary independently rather than assuming it is correct because the individual forms look reasonable.

Verify the employee contact information used for the chosen statement process. Route unresolved identity or address questions through controlled source records rather than changing them from an informal recollection.

For each finding, state the affected record, period, source, requested change, and reviewer. “Codes wrong” is not a useful instruction to the preparer.

Run population-wide checks where the available data supports them, then inspect representative forms and every material exception. Include ordinary full-year records and relevant change cases: hires, terminations, rehires, employer transfers, rate changes, and conditional covered-person reporting.

Select records from each source-system path. If half the workforce came through a converted administrator file, reviewing only the stable file path says little about the conversion. Likewise, inspect records affected by a preparation-rule change after that rule is revised.

Document how the review set was chosen. A sample can reveal problems and provide useful assurance about the inspected path, but it does not prove every record is correct. Expand the review when a finding suggests a systematic issue rather than merely fixing the first example.

Fictional Willow Ferry Partners prepares 240 records in draft v2. The reviewer examines 18 representative records and all seven logged exceptions. Two findings concern an outdated rate source that affects 36 people, so the preparer updates that source and regenerates draft v3.

The final review compares all 36 affected records to the corrected rate input and confirms that the population remains 240. The change report accounts for 36 revised records and 204 unchanged records: 36 + 204 = 240. The reviewer also checks that the resolved exception list matches v3.

The actual approval names draft v3, the reporting year, the employer, and the authorized next step. The fictional example demonstrates why approval of v2 cannot silently carry over to a materially changed v3.

A useful approval says what was reviewed, who completed each review, which exceptions remain, and what action is authorized. If an unresolved item prevents an accurate release, keep it visible and resolve it through the responsible reviewer rather than burying it in a general approval comment.

After approval, require a difference report for changed population, identities, monthly facts, or employer summaries. Refresh the review affected by those changes. Cosmetic output adjustments may need a narrower check, but the approver should still be able to identify the final version.

Keep approval separate from filing outcome. The IRS AIR resources address electronic filing; the employer's approval is a preparation milestone. Save the subsequent outcome with the same batch reference so the project can track both events accurately.