Compliance calendar · 2026, calendar-year plans
Every health-plan deadline, one page.
The filings and notices a group health plan owes across the year. Dates shown are for calendar-year plans — non-calendar plan years shift most of them.
January
1 deadline
Jan 31W-2 cost-of-coverage reportingReport aggregate employer-sponsored health coverage cost in Box 12-DD (employers filing 250+ W-2s).
March
3 deadlines
Mar 1Medicare Part D disclosure to CMSReport creditable-coverage status online within 60 days of plan-year start.
Mar 2Furnish Forms 1095-C / 1095-BDeliver individual coverage statements to employees (automatic 30-day extension from Jan 31).
Mar 31E-file Forms 1094-C / 1095-CElectronic filing deadline with the IRS — required for nearly all employers.
June
1 deadline
Jun 1RxDC prescription-drug reportAnnual pharmacy and health-spending data submission to CMS (usually handled by carrier/PBM — confirm it).
July
2 deadlines
Jul 31Form 5500 dueAnnual report for calendar-year ERISA plans — the $2,739/day one. File Form 5558 by today for a 2½-month extension.
Jul 31PCORI fee (Form 720)Self-insured plans pay the annual Patient-Centered Outcomes Research fee to the IRS.
September
1 deadline
Sep 30Summary Annual Report (SAR)Distribute the plain-language 5500 summary to participants — 9 months after plan-year end.
October
2 deadlines
Oct 14Medicare Part D notice to participantsCreditable-coverage notice to Medicare-eligible participants before annual enrollment opens Oct 15.
December
2 deadlines
Dec 15Extended SAR distributionSAR deadline for plans on a 5500 extension — 2 months after the extended filing date.
Dec 31Gag-clause attestation (GCPCA)Annual attestation to CMS that plan contracts contain no gag clauses on price/quality data (CAA §201).
Deep-dive guides
Full guides with embedded calculators and checklists.
- Form 5500 due date for calendar plansAnnual — last day of 7th month after PYE
- Form 5558 — 2.5-month Form 5500 extensionFiled by original Form 5500 due date
- When a Form 5500 large-plan audit becomes mandatoryPer plan year — participant count at start of plan year
- Schedule C — service-provider compensation disclosureAnnual — attached to Form 5500
- RxDC — Prescription Drug Data Collection annual deadlineAnnual — June 1
- Gag clause attestation — annual December 31 deadlineAnnual — December 31
- MHPAEA NQTL comparative analysis — what the documentation must coverOn request — typically within 10 business days of DOL request
- ACA employer-mandate affordability — 2026 plan yearsAnnual — IRS Revenue Procedure
- CAA 2021 broker compensation disclosure — the $1,000 rulePre-contract — at execution and at renewal
- DFVCP eligibility — only available before the DOL contacts youPer missed filing — eligibility window finite
- Section 125 cafeteria plan — the written-document requirementRequired at all times — adopt by plan effective date
NOTE
General information for calendar-year ERISA group health plans, current as of August 2026 — not legal advice. Deadlines differ for non-calendar plan years, small fully-insured plans (many are 5500-exempt), and plans with extensions. Confirm your dates with counsel or your TPA.
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