Benefits Compliance Calendar 2026–2027 | CTR Insurance & Benefits Services

Last reviewed October 2026

Dates assume a calendar-year plan (January 1 to December 31). A deadline that falls on a weekend or federal holiday moves to the next business day.

Still ahead in 2026

Date	Deadline	Who it applies to
Before open enrollment	Open enrollment packet: SBCs plus annual notices (CHIP, WHCRA, Medicare Part D)	All group health plans
Dec 15, 2026	Summary Annual Report (SAR) for plans with an extended Form 5500	Plans that filed Form 5558
Dec 31, 2026	Gag Clause Prohibition Compliance Attestation (GCPCA) to CMS	All group health plans (the carrier can attest for insured plans)
Dec 31, 2026	Section 125 nondiscrimination testing for the 2026 plan year, done before year end so corrections can still be made	Employers with a cafeteria plan

2027 calendar

Reporting for the 2026 plan year.

Date	Deadline	Who it applies to
Jan 1, 2027	New 2027 limits take effect (affordability, HSA, HDHP; see Key figures below)	All employers
Feb 1, 2027	Form W-2 to employees and SSA, with Box 12 codes DD (cost of employer health coverage) and W (HSA contributions). Jan 31 falls on a Sunday.	Code DD: employers filing 250+ W-2s. Code W: all employers with HSA contributions
Mar 1, 2027	Paper filing of Forms 1094-C/1095-C with the IRS (Feb 28 falls on a Sunday)	Applicable large employers (ALEs) filing fewer than 10 information returns in total
Mar 1, 2027	Form M-1 to the DOL	Multiple employer welfare arrangements (MEWAs)
Mar 1, 2027	Medicare Part D creditable coverage disclosure to CMS, due within 60 days of the plan year start	All employers offering prescription drug coverage
Mar 2, 2027	Furnish Form 1095-C to full-time employees, or post the on-request website notice and keep it up through Oct 15	ALEs (50+ full-time equivalents); self-insured plans of any size
Mar 31, 2027	Electronic filing of Forms 1094-C/1095-C. Form 8809 gives an automatic 30-day extension.	ALEs filing 10+ information returns in total (W-2s and 1099s count)
Jun 1, 2027	RxDC prescription drug and health care spending report to CMS for 2026	All group health plans (usually filed by the carrier, TPA, or PBM)
Aug 2, 2027	PCORI fee on Form 720 for the 2026 plan year. Jul 31 falls on a Saturday. The per-life amount is not yet announced.	Self-insured plans and HRAs (the carrier pays for fully insured plans)
Aug 2, 2027	Form 5500 for the 2026 plan year, or Form 5558 for a 2½-month extension. Jul 31 falls on a Saturday.	Welfare plans with 100+ participants, and funded or trust-based plans of any size
Sep 30, 2027	Summary Annual Report (SAR) to participants	Plans that filed a Form 5500 without an extension
Oct 14, 2027	Medicare Part D creditable or non-creditable coverage notice to Medicare-eligible individuals (must go out before Oct 15)	All employers offering prescription drug coverage
Oct 15, 2027	Extended Form 5500 due	Plans that filed Form 5558
Oct 15, 2027	Last day the 1095-C on-request notice must stay posted	ALEs using on-request furnishing
Before open enrollment	Open enrollment packet: SBCs plus annual notices (CHIP, WHCRA, Medicare Part D)	All group health plans
Dec 15, 2027	SAR for plans with an extended Form 5500	Plans that filed Form 5558
Dec 31, 2027	Gag Clause Prohibition Compliance Attestation (GCPCA) to CMS	All group health plans
Dec 31, 2027	Section 125 nondiscrimination testing for the 2027 plan year	Employers with a cafeteria plan

COBRA deadlines

Federal COBRA applies to employers with 20 or more employees. These clocks start from each qualifying event, so they repeat all year.

Step	Deadline	Who acts
General (initial) COBRA notice	Within 90 days after coverage begins	Plan administrator
Report a qualifying event (termination, reduced hours, death, Medicare entitlement)	Within 30 days of the event	Employer to plan administrator
Election notice	Within 14 days of being told of the event (44 days total when the employer is also the administrator)	Plan administrator
Report divorce, legal separation, or a child losing dependent status	Within 60 days of the event	Employee or qualified beneficiary
Election period	60 days from the later of the coverage loss or the election notice	Qualified beneficiary
First premium payment	Within 45 days after electing	Qualified beneficiary
Ongoing premium payments	30-day grace period after each due date	Qualified beneficiary
Disability extension notice (18 to 29 months)	Within 60 days of the Social Security disability determination, and before the 18 months end	Qualified beneficiary
Notice of unavailability	Within 14 days of denying a COBRA request	Plan administrator
Early termination notice	As soon as practicable after deciding coverage will end early	Plan administrator

Maximum coverage: 18 months for termination or reduced hours, 29 months with a disability extension, and 36 months for divorce, death, Medicare entitlement, or a child losing dependent status.

Pennsylvania mini-COBRA. For insured plans of employers with 2 to 19 employees, Pennsylvania law (Act 2 of 2009) provides up to 9 months of continuation. The carrier usually administers it, so confirm notice and election timelines with the carrier.

Other ERISA and ACA notices

These notices are tied to enrollment, plan changes, or requests rather than a fixed calendar date.

Notice	When it’s due
Summary of Benefits and Coverage (SBC)	With enrollment materials, at initial and special enrollment, and within 7 business days of a request
Mid-year SBC change	60 days before a material change takes effect
Summary Plan Description (SPD)	Within 90 days after someone becomes covered; restated every 5 years if amended (every 10 years if not)
Summary of Material Modifications (SMM)	Within 210 days after the end of the plan year in which a change is adopted; within 60 days for a material reduction in group health benefits
HIPAA special enrollment notice	At or before the time an employee is offered enrollment
HIPAA privacy notice	At enrollment, with a reminder at least every 3 years (self-insured plans, or insured plans that receive PHI)
CHIP premium assistance notice	Annually, usually with open enrollment
Women’s Health and Cancer Rights Act (WHCRA) notice	At enrollment and annually
Medicare Part D notice	Before Oct 15 each year, at enrollment, when creditable status changes, and on request
Marketplace (Exchange) notice	Within 14 days of hire
Michelle’s Law notice	With any request to certify a dependent’s student status
Mental health parity (MHPAEA) comparative analysis	Kept on file and provided on request from the DOL or participants

Key figures, 2026 and 2027

Item	2026	2027
ACA affordability percentage	9.96%	10.22% (Rev. Proc. 2026-26)
4980H(a) penalty, per full-time employee per year	$3,340	$3,780 ($315/month)
4980H(b) penalty, per employee receiving a premium tax credit per year	$5,010	$5,670 ($472.50/month)
PCORI fee per covered life, paid by July 31	$3.84 (2025 plan year, Notice 2025-61)	Not yet announced (2026 plan year)
HSA limit, self-only / family	$4,400 / $8,750	$4,500 / $9,000
HSA catch-up (age 55+)	$1,000	$1,000
HDHP minimum deductible, self-only / family	$1,700 / $3,400	$1,750 / $3,500
HDHP out-of-pocket maximum, self-only / family	$8,500 / $17,000	$8,700 / $17,400
Excepted benefit HRA	$2,200	$2,250
Health FSA salary reduction limit	$3,400	Not yet announced
Dependent care FSA	$7,500	$7,500

The 2027 federal poverty line safe harbor caps employee-only premiums at $135.93 a month in the lower 48 states and D.C.

This calendar summarizes federal requirements for planning. It isn’t legal or tax advice, and your plan year, headcount and funding model change what applies. Ask us and we will confirm the deadlines for your plan in writing.

Benefits compliance calendar.

Still ahead in 2026

2027 calendar

COBRA deadlines

Other ERISA and ACA notices

Key figures, 2026 and 2027

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