Compliance | HR Insights

2026 Federal Benefit Compliance Calendar
September 2025

Oct 6, 2025

Calendar

MonthRequirementDue DateDescription
JanuaryW-2sJan 31Employers that filed at least 250 W-2s in the previous year must report the cost of coverage (employer and employee contributions) in Box 12 (Code DD).

Employers must report all employer contributions to employees’ HSAs in Box 12 (Code W).

Employers must report dependent care benefits paid or incurred in Box 10. Amounts over $5,000 ($2,500 in the case of a separate return filed by a married individual) are also included in Box 1.
MarchPart D Creditable Coverage Report due to CMS (for calendar year plans*)Mar 1Employers sponsoring prescription drug plans must report creditable status to CMS within 60 days after the beginning of the plan year.
*See Appendix for non calendar year plan due dates
MarchHIPAA Breach Notifications due to OCRMar 1Employers sponsoring group health plans must report any breach of Protected Health Information (PHI) affecting fewer than 500 individuals to OCR within 60 days of the end of the calendar year (regardless of when the plan year ends).
March1095-B and 1095-C Forms due to individualsMar 2Applicable Large Employers (50 or more FTEs) must provide offer of coverage information for the 2025 calendar year to employees (copies of 1095-Cs). Employers with self-funded plans must provide coverage information to covered individuals (copies of 1095 Bs or 1095-Cs).

In addition, employers must comply with state-level requirements to provide Form 1095s to covered individuals residing in California, New Jersey, Rhode Island, and the District of Columbia and Form 1099-HCs to covered individuals residing in Massachusetts. The due dates for this requirement vary by state.
March1094-B, 1095-B, 1094-C, and 1095-C Forms due to IRSMar 31Applicable Large Employers (50 or more FTEs) and employers with self-funded plans must report offer and coverage information for the 2025 calendar year on Forms 1094 and 1095.
AprilLast day for 2025 HSA contributions or correctionsApr 15Employers and individuals have until the tax filing deadline to make HSA contributions and corrections for a given calendar year.
JunePrescription Drug ReportingJun 1Due date for reporting data for the 2025 calendar year.
JulyLast day to issue a Summary of Material Modification (SMM) for the prior plan year (for calendar year plans*)Jul 28

ERISA requires that an SMM be issued any time there is a change in a plan provision that is “material” or any time there is a change in a plan provision that is required to be in the Summary Plan Description (SPD). The due date is 210 days after the end of the plan year to which the change applies, 60 days following the adoption of a material reduction. *See Appendix for non-calendar year plan due dates
JulyPCORI FeeJul 31Patient-Centered Outcomes Research Institute (PCORI) fee is due for policy or plan years that ended in 2025.
July5500 Filing (for calendar year plans*)Jul 31Employers must file 5500s for plans with at least 100 participants (i.e., employees) at the start of the plan year. In addition, employers with plans that have fewer than 100 participants must file a 5500 if the plan is “funded” (i.e., the assets of the plan are segregated from the general assets of the plan sponsor through a trust). *See Appendix for non-calendar year plan due dates
SeptemberSummary Annual Report (SAR) (for calendar year plans*)

Sept 30


A SAR is a summary of the Form 5500 and is required for any plan subject to Form 5500 filing, but not for unfunded, self-funded plans (where claims are paid from the employer’s general assets). It is due within 9 months of the close of the plan year.
*See Appendix for non-calendar year plan due dates
SeptemberMLR Rebates (Due date for carriers to issue rebates)Sept 30Carriers are required to report prior year MLR data to HHS by July 31 and to distribute rebates to employers by September 30 if the MLRs are not met.
OctoberMedicare Part D Creditable Coverage Notices due to Individuals
Oct 15Employers offering prescription drug coverage must issue a creditable (or non creditable) notice to individuals by October 14 (employers may provide the notice at any time during the 12 months preceding October 15 –e.g., during the previous open enrollment).
October5500 Filing Due Date with Extension (for calendar year plans*)Oct 15Employers must file 5500s for plans with at least 100 participants (i.e., employees) at the start of the plan year. In addition, employers with plans that have fewer than 100 participants must file a 5500 if the plan is “funded” (i.e., the assets of the plan are segregated from the general assets of the plan sponsor through a trust). *See Appendix for non-calendar year due dates
DecemberLast day for employer to distribute portion of MLR rebate that is considered plan assetsDec 29Employers sponsoring fully-insured group health plans must distribute the portion of an MLR Rebate that is considered plan assets to current plan participants (e.g., as cash or as a premium holiday) within 90 days of receipt. Otherwise, the employer may be subject to ERISA trust requirements.
DecemberGag Clause AttestationsDec 31Employers and carriers must submit an attestation of compliance with the gag clause prohibition contained in the Consolidated Appropriations Act (CAA).

Appendix – Due Dates for Non-Calendar Year Plans

Medicare Part D Disclosures
(Due 60 days after the start of the plan year)
Plan Year BeginningMedicare Part D Creditable Coverage Reporting Due to CMS
December 1, 2025January 30, 2026
January 1, 2026March 1, 2026
February 1, 2026March 31, 2026
March 1, 2026April 30, 2026
April 1, 2026May 31, 2026
May 1, 2026June 30, 2026
June 1, 2026July 31, 2026
July 1, 2026August 30, 2026
August 1, 2026September 30, 2026
September 1, 2026October 31, 2026
October 1, 2026November 30, 2026
November 1, 2026December 31, 2026
5500 Reporting
(Due the last day of the 7th month after the end of the plan year)
Plan Year Ending5500 DueDue Date with Extension
June 30, 2025January 31, 2026April 15, 2026
July 31, 2025February 28, 2026May 15, 2026
August 31, 2025March 31, 2026June 15, 2026
September 30, 2025April 30, 2026July 15, 2026
October 31, 2025May 31, 2026August 15, 2026
November 30, 2025June 30, 2026September 15, 2026
December 31, 2025July 31, 2026October 15, 2026
January 31, 2026August 31, 2026November 15, 2026
February 28, 2026September 30, 2026December 15, 2026
March 31, 2026October 31, 2026January 15, 2027
April 30, 2026November 30, 2026February 15, 2027
May 31, 2026December 31, 2026March 15, 2027
Summary of Material Modifications
(Due within 210 days after end of plan year)
Plan Year EndingSMM Due
June 30, 2025January 26, 2026
July 31, 2025February 26, 2026
August 31, 2025March 29, 2026
September 30, 2025April 28, 2026
October 31, 2025May 29, 2026
November 30, 2025June 28, 2026
December 31, 2025July 29, 2026
January 31, 2026August 29, 2026
February 28, 2026September 26, 2026
March 31, 2026October 27, 2026
April 30, 2026November 26, 2026
May 31, 2026December 27, 2026
Summary Annual Report (SAR)
(Due within 9 months after end of the plan year)
Plan Year EndingSAR Due
April 30, 2025January 30, 2026
May 31, 2025February 28, 2026
June 30, 2025March 30, 2026
July 31, 2025April 30, 2026
August 31, 2025May 31, 2026
September 30, 2025June 30, 2026
October 31, 2025July 31, 2026
November 30, 2025August 30, 2026
December 31, 2025September 30, 2026
January 31, 2026October 31, 2026
February 28, 2026November 28, 2026
March 31, 2026December 31, 2026
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