2026 Health Plan Compliance Deadlines
Following are the published deadlines (so far) for employer-sponsored health plan reporting:
| Deadline | Required Report | Who Must Report |
|---|---|---|
| 2/2/26 | Health Plan Costs on Form W-2 | Employers filing 250 or more W-2 forms for 2025 |
| 3/1/26 | Medicare Part D disclosure to CMS | Group health plans providing prescription drug coverage to Medicare Part D participants |
| 3/2/26 | Notify employees of availability of copy of ACA form 1095-C | Employers that are Applicable Large Employers (ALEs) (i.e., 50 employees or more) |
| 3/2/26 | Notify employees of availability of copy of ACA form 1095-B | Employers that are NOT Applicable Large Employers (ALEs). (Must respond within 30 days to request for either 1095-C or 1095-B) |
| 3/31/26 | Electronically file ACA forms 1094-B and 1094-C with IRS | Applies to both ALEs and non-ALEs that have self-insured health coverage plans |
| 6/1/26 | Submit Drug Data Collection Report (RxDC) | Health plans and insurance carriers |
| 7/31/26 | Report and pay PCORI fee | Employers with self-insured health plans (pays for Patient-Centered Outcomes Research Institute [PCORI]) |
| 7/31/26 | File Form 5500 | Required from all employers with welfare benefit plans that are covered by ERISA |
| 9/30/26 | Watch for MLR rebates | Employers with insured health plans may receive rebates if they do not meet their applicable medical loss ratio (MLR) percentage |
| 9/30/26 | Provide Summary Annual Report (SAR) to participants | Employers that must file Form 5500 and have not received an extended deadline for submission |
| 10/3/26 | Provide ICHRA notice for plan year in 2027 | Employers offering “individual coverage health reimbursement arrangements” (ICHRAs). Must be provided 90 days prior to beginning of plan year. |
| 10/3/26 | Provide QSECHRA notice for plan year in 2027 | Employers offering qualified small employer health reimbursement arrangements (QSEHRAs). Must be provided 90 days prior to beginning of plan year. |
| 10/14/26 | Provide Medicare Part D Notices | Group health plans providing prescription drug coverage to persons eligible for Medicare Part D |
| 10/15/26 | Extended Deadline to File Form 5500 | Deadline must have been officially extended prior to original deadline of 7/31 |
| 12/15/26 | Extended Deadline to provide SAR (applies to calendar-year plans) | Typical deadline if extension from 9/30 is granted |
| 12/31/26 | Submit gag clause attestation | Signifies compliance with federal prohibition on gag clauses for group insurance providers |
