Throughout the year, employers must comply with numerous reporting and disclosure requirements related to their group health plans. This Compliance Overview identifies key 2026 compliance deadlines for employer-sponsored group health plans. It also outlines group health plan notices employers must provide each year.
Some compliance deadlines summarized below are tied to a group health plan’s plan year. For these requirements, the chart below shows the deadline that applies to calendar-year plans. For noncalendar-year plans, these deadlines will need to be adjusted to reflect each plan’s specific plan year.
Determining the Plan Year
The “plan year” is the calendar, policy or fiscal year on which the records of the plan are kept. Many employers operate their group health plans on a calendar-year basis from Jan. 1 through Dec. 31 of each year. Other employers operate their plans on a noncalendar-year basis, which may be consistent with the company’s taxable year or with an insured plan’s policy year.
2026 Compliance Deadlines
The Compliance Overview below includes the following 2026 compliance deadlines:
- February 2, 2026: Report health plan costs on Form W-2.
- March 1, 2026 (Calendar-year plans): Submit Medicare Part D disclosure to the CMS.
- March 2, 2026: Notify employees about the availability of ACA Form 1095-C (or automatically furnish these statements).
- March 2, 2026: Notify employees about the availability of ACA Form 1095-B (or automatically furnish these statements).
- March 31, 2026: Electronically file ACA Forms 1094-C and 1095-C.
- March 31, 2026: Electronically file ACA Form 1094-B and 1094-C.
- June 1, 2026: Submit the prescription drug data collection report.
- July 31, 2026: Report and pay PCORI fee.
- July 31, 2026 (Calendar-year plans): File Form 5500 (regular deadline).
- September 30, 2026: Watch for MLR rebates.
- September 30, 2026 (Calendar-year plans): Provide a SAR (regular deadline).
- October 3, 2026 (Calendar-year plans): Provide ICHRA notice for 2027 plan year.
- October 3, 2026 (Calendar-year plans): Provide QSEHRA notice for 2027 plan year.
- October 14, 2026: Provide Medicare Part D notices.
- October 15, 2026 (Calendar-year plans): File Form 5500 (extended deadline).
- December 15, 2026 (Calendar-year plans): Provide SAR (extended deadline).
- December 31, 2026: Submit gag clause attestation.
Annual Notices
It also includes the following group health plan notices:
- SBC: Group health plans and health insurance issuers
- WHCRA Notice: Group health plans that provide medical and surgical benefits for mastectomies
- CHIP Notice: Group health plans that cover residents in a state that provides a premium assistance subsidy under a Medicaid plan or CHIP
- SPD & SMM: Group health plans subject to ERISA
- COBRA General Notice: Group health plans subject to COBRA
- Grandfathered Plan Notice: Health plans that have grandfathered status under the ACA
- Notice of Patient Protections: Group health plans that require the designation of a participating primary care provider
- HIPAA Privacy Notice: Self-insured group health plans
- HIPAA Special Enrollment Notice: All group health plans
- Wellness Notice – HIPAA: Group health plans with health-contingent wellness programs
- Wellness Notice – ADA: Wellness programs that collect health information or include medical exams
This article is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel for legal advice. ©2025 Zywave, Inc. All rights reserved.
