Q4 Benefits Compliance: Your Year-End Checklist

The fourth quarter is more than open-enrollment season. Employers and plan administrators also need to complete filings, distribute notices, review participant disclosures, and prepare plan documents for the year ahead. 

Not every requirement applies to every employer. Confirm your plan’s requirements, exemptions, and extension status with benefits counsel, administrators, recordkeepers, and insurance providers.

Timing What to Check Who needs to review it Before October 15 Annual Medicare Part D coverage disclosure. Group health plans subject to the disclosure rules; provide the notice to applicable Part D-eligible individuals enrolled in or seeking prescription coverage. October 15 Extended 2025 Form 5500 or Form 5500-SF Applicable calendar-year retirement and welfare plans that obtained a Form 5558 extension. October 15 Extended Form 8955-SSA and related participant statements Applicable retirement plans with reportable deferred vested participants and an extension. October 15 PBGC premium filing and payment PBGC-covered calendar-year defined benefit plans.

October 15 is an extended filing deadline only where the required extension was obtained not a new deadline for plans that missed their original filing date. The Medicare notice must be provided before October 15. 

Check Your Open-Enrollment Packet 

Sending one packet does not automatically satisfy every notice requirement. Check each item’s recipients, timing, and delivery method. 

• Summary of Benefits and Coverage: SBCs generally belong with written enrollment materials. Where reenrollment is automatic, the guide generally identifies December 1 for coverage beginning with the 2027 calendar-year plan year. 

• WHCRA notice: Provide the required annual Women’s Health and Cancer Rights Act notice to participants and beneficiaries. It may accompany open-enrollment materials or an annually distributed summary plan description. 

• CHIP notice: Where applicable, provide the annual Medicaid and Children’s Health Insurance Program premium-assistance notice to all employees not only those enrolled in the health plan. 

Schedule Retirement Notices 

Certain retirement arrangements require notices before the next plan year begins.

Notice Calendar-year timing Qualified Default Investment Alternative notice December 1, or sooner where necessary to provide a reasonable period before the next plan year. . Eligible Automatic Contribution Arrangement notice Generally October 2–December 1, with earlier delivery within that window where needed to allow participant action. Qualified Automatic Contribution Arrangement notice Generally October 2–December 1, subject to participant-response timing requirements. Traditional safe-harbor 401(k) notice Generally October 2–December 1, where the notice requirement applies. Certain safe-harbor nonelective contribution plans are exempt.

Have your recordkeeper identify which notices apply. If notices are combined, confirm that the delivery date satisfies every applicable timing requirement. 

Review Changes and Year-End Tasks 

Here are some highlights to discuss with your providers: 

• Paper benefit statements: Defined contribution plans generally must furnish at least one benefit statement on paper each calendar year unless an exception applies. The guide notes temporary good-faith compliance relief for 2026. Defined benefit statements have separate paper-delivery rules and exceptions. 

• PBGC payments: The paper-check payment option is no longer available in 2026. Confirm payment arrangements before the applicable deadline. 

• December 15 - Summary Annual Reports: Applicable calendar-year plans with the relevant extension must furnish their reports, subject to plan-specific exemptions and distribution rules. 

• December 31 - Plan amendments: Confirm whether your qualified plan needs amendments under the extended deadlines involving the SECURE Act, CARES Act, or SECURE 2.0. 

• December 31 - Gag-clause attestation: Covered group health plans, including applicable fully insured and self-insured arrangements, must submit their annual compliance attestation. Limited exceptions apply.