What is an Aggregated ALE Group?

An Aggregated ALE Group is a group of ALE Members (employers) treated as a single employer for the purposes of 1095 filing. Companies with a common owner or are otherwise related are considered part of an Aggregated ALE Group.

When determining ALE status, full time employees and full time equivalents for each of the members of the Aggregated ALE Group are combined. Example:

  • Corporation X owns 100 percent of all classes of stock of Corporation Y and Corporation Z.
  • Corporation X has no employees at any time in 2019.
  • For every calendar month in 2020, Corporation Y has 40 full-time employees and Corporation Z has 60 full-time employees. Neither Corporation Y nor Corporation Z has any full-time equivalent employees.
  • Corporations X, Y, and Z are considered a controlled group of corporations.
  • Because Corporations X, Y and Z have a combined total of 100 full-time employees for each month during 2020, Corporations X, Y, and Z together are an ALE for 2021.
  • Corporation Y and Z are each an ALE member for 2021.
  • Corporation X is not an ALE member for 2021 because it does not have any employees during 2020.

Each member of an Aggregated ALE group is liable for filing 1095 forms for their employees. In the above example, 1095-C forms will be filed for the employees who worked for Corporations Y and Z. In addition, separate authoritative 1094-C forms will need to be filed for both Corporation Y and Corporation Z. Each member of an Aggregated ALE Group will need to file one authoritative 1094-C form per tax year.

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