Section 2
0926 Publ 5165 (PDF) · 2026-10-03 edition · updated 2026-10-04 · United States
Submitting the ACA Application for Transmitter Control Code (TCC)
If you are an employer or insurance issuer/carrier responsible for filing 10 or more ACA Information Returns, you are required to file them electronically. ACA Information Returns must be filed through AIR using an ACA Transmitter Control Code (TCC). ACA Information Returns may not be filed using any other Transmitter Control Code. For example, FIRE TCC or Electronic Identification Filing Number (EFIN).
Treas. Reg. (TD 9972) reduces the threshold from 250 to 10 and requires corrected information returns to be filed in the same manner as original information returns.
“Who should apply for an ACA Transmitter Control Code”?
If you are transmitting information returns to IRS or if you are developing software to file information returns electronically, you must apply for one or more TCCs using the ACA Application for Transmitter Control Code (TCC) available online from e-Services . A single application can be used to apply for multiple roles and the necessary TCCs.
The ACA Application for TCC contains three separate roles: Software Developer, Transmitter, and Issuer.
Complete the ACA Application for TCC if your firm or organization is performing one or more of the following roles:
- Software Developer – An organization writing either origination or transmission software according to
IRS specifications.
- Transmitter – A Third-Party sending the electronic information returns data directly to IRS on behalf of
any business.
Note: If you are transmitting returns for your own company, in addition to transmitting returns on behalf of another business, you do not need both the Transmitter and Issuer role. You can file all returns as a Transmitter.
- Issuer – A business filing their own ACA Information Returns regardless of whether they are required
to file electronically (transmit 10 or more of the same type of information return) or volunteer to file electronically. The term “Issuer” includes any person required to report coverage on Form 1095-B and any applicable large employer required to report offers of coverage on Form 1095-C and file the associated transmittal Form 1094-B or Form 1094-C.
Treas. Reg. (TD 9972) reduces the threshold from 250 to 100 and requires corrected information returns to be filed in the same manner as original information returns.
If you are an Employer or Insurance Issuer/Carrier using a Third Party to prepare and transmit your information returns to IRS, you do not need to obtain a TCC.
Note: Issuers and Transmitters are collectively referred to as Transmitters throughout this document.
These roles are not mutually exclusive, for example, a firm or organization may be both a Transmitter and a Software Developer. In addition to the roles the firm or organization will perform, the application will require the transmission method for Transmitters and Issuers or the transmission method(s) the software packages will support.
Guide for Electronically Filing ACA Information Returns for Software Developers and Transmitters 6
Submitting the ACA Application for Transmitter Control Code (TCC)
Each role will receive its own TCC to be used based on the activity being performed. For example, Software Developers performing Testing will use the Software Developer TCC. Do not use the Software Developer TCC to transmit Production files.
Note: If an organization requires more than one TCC for any given role, a Responsible Official listed on the application should contact the AIR help desk to request an additional TCC.
The table below provides examples of who should apply for a TCC.
Table 2-1: TCC Roles
What roles should I select on my ACA Application for Transmitter Control Code?
Software Purchased or
Developed?
If… And Then
| Developed | I am a commercial Software Developer developing software and selling software packages to employers and insurance issuers/ |
I will transmit information for employers or insurance issuers/ carriers. |
Select both the Software Developer role and the Transmitter role on your application. |
|---|---|---|---|
| Developed | I am an employer or insurance issuer/ developing my own software package, or who has contracted with someone to develop a unique package for my sole use, |
I will perform the software testing with IRS and transmit my own information returns. |
Select the roles of Software Developer and Issuer on your application. |
| Purchased | I am an employer or insurance issuer/ purchasing a software package, |
I will transmit my own information returns. |
Select the role of Issuer on your application. Note: You may not use an Issuer TCC to transmit information returns for other employers or insurance issuers/ |
Guide for Electronically Filing ACA Information Returns for Software Developers and Transmitters 7
Submitting the ACA Application for Transmitter Control Code (TCC)
What roles should I select on my ACA Application for Transmitter Control Code?
E-Services transitioned the AIR Production application to a modernized sign-in system that requires users to register and sign in with ID.me to access the e-Services suite of online applications. ID.me is an account created, maintained, and secured by a technology provider. Responsible Officials and Contacts must create an e-Services account before they can apply for a TCC. Each Responsible Official will need to sign the ACA Application for TCC on the Application Submission page by accepting the Terms of Agreement box and entering their PIN created during the registration process. Below are the available titles for Responsible Officials.
Guide for Electronically Filing ACA Information Returns for Software Developers and Transmitters 8
Submitting the ACA Application for Transmitter Control Code (TCC)
Table 2-2: Responsible Official Titles
| Business Type | Title |
|---|---|
| Partnership and Limited Liability Partnership |
Partner, General Partner, Limited Partner, LLC Member, Manager, Member, Managing Member, President, Owner, Tax Matter Partner (TMP) |
| Corporations, Personal Service Corporation and Limited Liability Corporations |
President, Vice President, Corporate Treasurer/ Treasurer, Chief Accounting Offcer (CAO), Chief Executive Offcer (CEO), Chief Financial Offcer (CFO), Tax Offcer, Chief Operating Offcer (COO), Corporate Secretary/ |
| Association, Credit Union, Volunteer Organization, State Government Agency |
President, Vice President, Treasurer, Assistant Treasurer, Chief Accounting Offcer (CAO), Tax Offcer, Chief Operating Offcer (COO), Chief Executive Offcer (CEO), Chief Financial Offcer (CFO), Executive Director/ Receiver, Pastor, Assistant to Religious Leader, Reverend, Priest, Minister, Rabbi, Chairman, Secretary, Director of Taxation, Director of Personnel, Tax Offcer |
| Sole Proprietor | Owner, Sole Proprietor, Member, Sole Member, Tribes |
After all listed Responsible Officials have entered their PIN on the Application Submission page, submit the application for processing.
Note: All Responsible Officials and Contacts on the application must create an account by registering and signing in with ID.me to access the e-Services suite of online applications before the application can be submitted.
Responsible Official – Individuals with responsibility for, or the authority over the electronic filing of ACA Information Returns operation at the firm or organization location. Responsible Officials are also the first point of contact with IRS, and have authority to sign original/revised ACA Application for TCC and are responsible for ensuring that all requirements are adhered to. At least two Responsible Officials will need to be listed on the application. All Responsible Officials will be required to sign the application. A Responsible Official can also be a Contact on the application.
Contact – individuals who may be responsible for transmitting and/or are available for inquiries from IRS daily. There is a minimum of 2 required Contacts and a maximum of 10 Contacts allowed per application.
Note: The Contact provided here is not required to be the same Contact provided on the Form 1094-B or Form 1094-C.
The application does not have to be completed in a single session. A tracking number is provided when the application is submitted or when the application is in “Saved” status.
Note: In certain situations, the information submitted requires further review by IRS before a TCC can be issued. In these cases, IRS will contact the Responsible Official of record regarding any additional information that may be needed.
Guide for Electronically Filing ACA Information Returns for Software Developers and Transmitters 9
Submitting the ACA Application for Transmitter Control Code (TCC)
Once an ACA Application for TCC is processed and completed, TCCs and Software IDs, if applicable, are sent via United States Postal Service (USPS) and are also available to be viewed on the summary screen of the applicant’s online application. Applicants will receive a separate letter containing the TCC for each role selected on their application.
2.1 | Transmitter and Issuer TCCs
Depending on the roles selected on the application, one or more TCCs will be assigned. Each TCC will have an indicator of Test "T" or Production "P" and status of Active, Inactive, or Dropped. Transmitters and Issuers are issued a TCC in Production status. The Form T/P Indicator (1094/1095-B or 1094/1095-C) is in Test “T” status, until required Communication Testing is conducted and passed. See the example 2-1 below. Once Communication Testing is passed, the Transmitter should contact the AIR Help Desk, toll-free, at 1-866-9374130, to request the associated Form T/P Indicators be moved to Production “P” status. Transmitters must then wait 48 hours after the Form T/P Indicators are moved to Production before they can use the TCC to transmit live data to Production. Once a Form T/P Indicator is moved to Production, the TCC cannot be used to transmit to the test environment. See the example below:
Figure 2-1: Example of Transmitter TCC and Form Status
2.2 | Software Developer TCCs
After selecting the Software Developer role on the application, additional information about the transmission method and the software package (type, year and forms supported) being developed is required. The TCC is permanently assigned in “Test” status. A separate Software ID is also assigned for each package. The tax year(s) for the information returns supported, transmission method(s), form type, and software package type (Commercial Off the Shelf (COTS), Online, In-house) are also required. Each Software Package and form type has a separate status; if your Software Package supports more than one form type (e.g. Forms 1094/1095-B and 1094/1095-C), both forms must be in Production before the Software Package is moved from "Test" status to "Production" status.
Guide for Electronically Filing ACA Information Returns for Software Developers and Transmitters 10
Submitting the ACA Application for Transmitter Control Code (TCC)
Figure 2-2: Software Package Identifiers and Status Indicators
Software Package information must be updated annually through the ACA Application for TCC located on e-Services at IRS.gov . New Software IDs will be assigned for each tax year. To update your application, the Responsible Official should go to the Application Details page and click the "Add" button under the Software Developer Package List.
Figure 2-3: Add Software Developer Package
Guide for Electronically Filing ACA Information Returns for Software Developers and Transmitters 11
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