IRS Enables E-filing for Forms 1120-PC and 1120-L for 2026 Process Year

In Brief:

• Benefits to include faster acknowledgements, reduced risk of delays
• Options for integrated payment and refunds available
• E-filing forms available in mid-2026

Beginning this year, insurance companies will be able to electronically file (e-file) Form 1120-PC U.S. Property and Casualty Insurance Company Income Tax Return and Form 1120-L U.S. Life Insurance Company Income Tax Return through the IRS’s Modernized e-File (MeF) system.

This is the first time in the history of these insurance tax filings that the IRS has both permitted electronic filing of Forms 1120-PC and 1120-L, and it marks a significant change going forward. The change is notable because it modernizes the filing process, aligns insurance company filings with broader corporate e-filing requirements, and is part of the IRS’s ongoing digital transformation.

Among the expected benefits of e-filing these forms will be faster acknowledgments, reduced risk of lost or delayed returns, capability for integrated payment and refund options, and improved accuracy and efficiency of return processing.

Key details of this development include:

Availability: Both Form 1120-PC and Form 1120-L will be supported in XML format for e-filing beginning in mid-2026.

This means insurance companies can prepare and submit these returns electronically for tax years 2025, 2024, and 2023, as well as for future years, as permitted by the MeF system’s three-year window for e-filed returns.

Consolidated and mixed group returns: For consolidated returns where a Form 1120 is the parent and one or more subsidiaries file Form 1120-PC or Form 1120-L, the subsidiary returns must be submitted in XML format as part of the consolidated e-filed return. Each subgroup (1120, 1120-PC, 1120-L) must be reported separately, and required schedules such as Schedule M-3 and Form 8916 must be included at each level.

Signature requirements: The electronic return must be signed using the appropriate method, such as the scanned Form 8453-CORP for corporations, which must be attached as a PDF to the electronic submission. The signature of the authorized officer is required prior to transmission.

Supporting documentation: All required forms, schedules, and supporting statements must be included in the electronic submission. Where IRS schemas are not available for certain attachments, PDF files with straightforward names and descriptions should be used.

Requirement for NAIC annual statement: Historically, insurance companies filing Forms 1120-PC and 1120-L were required to submit their returns on paper, and the NAIC annual statement (or pro forma annual statement for certain foreign insurers) was to be attached to the paper return.

The 2025 Instructions for Form 1120-PC and the 2025 Instructions for Form 1120-L both state that these forms can now be filed electronically, and the NAIC annual statement should not be attached to the e-filed return but must be retained and provided to the IRS upon request.

Recordkeeping: Taxpayers and providers must retain a complete copy of the electronic return, including all schedules, attachments, and the signed declaration, for at least three years from the due date or extended due date of the return.

This expansion of e-filing options reflects the IRS’s commitment to modernizing tax administration and making compliance easier for insurance companies. For more information, including technical requirements and instructions for e-filing, refer to IRS Publication 4163 and the IRS MeF program information page.

Insurance companies and their tax professionals are encouraged to work with their software providers to ensure readiness for these new e-filing capabilities as the 2026 filing season approaches.

Recent regulatory changes and e–file mandate: For tax years beginning after December 31, 2023, the IRS has implemented mandatory electronic filing for corporations, including insurance companies, that file 10 or more returns of any type during the calendar year. This is a result of the Taxpayer First Act and the final regulations in T.D. 9972, which lowered the e-filing threshold and explicitly included insurance company returns such as Forms1120-PC and 1120-L [1].

Electronic Signatures: The IRS has also permanently extended the ability to use electronic signatures for these forms, further supporting the transition to digital filing.

We’re Here to Help

If you have any questions about the e-filing process for Form 1120-PC and Form 1120-L, please contact your JLK Rosenberger team member, call 818-334-8623, or click here to contact us. We look forward to speaking with you soon.