Key Q4 Compliance Deadlines for Defined Benefit Plans* *This chart is for private-sector, single-employer defined benefit plans that are subject to ERISA and that use a calendar-year plan year . It covers annual and periodic notice and reporting requirements with deadlines that fall (or could fall) within Q4; it generally does not cover initial or event-based requirements. Key Q4 Compliance Deadlines for Employer-Sponsored Group Health Plans* *This chart is for private-sector, employer-sponsored group health plans that are subject to ERISA and use a calendar-year plan year . It covers annual and periodic notice and reporting requirements that fall (or could fall) within Q4; it generally does not cover initial, event-based, or “upon request” requirements.
2026 ONLY
Deadline
Requirement
Action Item
Deadline
Requirement Form 5500 (or Form 5500-SF, as applicable) (ERISA § 104) Note: Small plans meeting certain conditions are exempt from this requirement. Extended deadline to amend qualified plans for certain required and discretionary amendments, including under the SECURE Act, CARES Act, and SECURE 2.0 Act (IRS Notice 2024-2) Annual Medicare Part D Notice of Creditable Coverage (42 CFR § 423.56(c)) Note: This requirement generally applies to group health plans that offer prescription drug coverage, subject to limited exceptions.
Action Item
Ensure plan is properly amended for any applicable required amendments. Discretionary amendments implementing SECURE, CARES, or SECURE 2.0 provisions may be adopted by December 31, Provide required disclosures to Part D-eligible individuals enrolled or seeking to enroll in the plan’s prescription drug coverage 2026, even if operationally implemented in prior years. Complete and file Form 5500/Form 5500-SF (and any required schedules and attachments) electronically using the DOL’s EFAST2 system Note: Group health plans subject to the Part D disclosure rules also must submit an annual disclosure to CMS regarding creditable coverage status of their prescription drug plan. This annual disclosure must be submitted online by March 2 of the applicable plan year. Learn more here.
October 15, 2026 (for the 2025 plan year), if a Form 5558 filing extension was obtained (otherwise, the deadline was July 31, 2026)
December 31, 2026
Prior to October 15, 2026 (prior to the commencement of the Annual Coordinated Election Period, which runs October 15 to December 7, for the following calendar year) Note: This is the deadline for the annual notice only; other distribution timing requirements apply.
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