Key Q4 Compliance Deadlines for Employer-Sponsored Group Health Plans*
Deadline
Requirement
Action Item
Provide an SBC (for each benefit package offered for the 2027 plan year) to each eligible participant and beneficiary, either in paper form or, if certain criteria are met, electronically Note: A single SBC may be provided to a participant and their beneficiaries (if any) at the participant’s last known address, unless a beneficiary’s last known address is different from the participant’s (in which case a separate SBC must be provided to the beneficiary at their last known address).
Summary of Benefits and Coverage (SBC) (29 § C.F.R. 2590-715-215) Note: A fully insured group health plan can satisfy the SBC requirement if the insurance issuer provides timely and complete SBCs to the individuals.
Various timing requirements. In the context of annual enrollment, SBC(s) generally must be included as part of the written enrollment/application materials. However, if reenrollment is automatic , SBCs generally must be provided by December 1, 2026 (regarding coverage for the 2027 plan year).
Summary Annual Report
(29 C.F.R. § 2520.104b-10)
Furnish a Summary Annual Report to each participant (no requirement to send to beneficiaries)
December 15, 2026 (for the 2025 plan year), if a Form 5558 filing extension was obtained (otherwise, the deadline was September 30, 2026)
Note: Certain welfare plans, including totally unfunded plans and plans exempt from the Form 5500 filing requirement, are exempt from this requirement.
Annual Gag Clause Prohibition Compliance Attestation (ERISA § 724, IRC § 9824, and Public Health Service Act § 2799A-9) Note: This requirement applies to (in addition to certain health insurance issuers) fully insured and self-insured group health plans (including ERISA plans) but excluding plans offering only excepted benefits (among other limited exceptions).
Submit the attestation electronically using the Health Insurance and Oversight System.
December 31, 2026
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