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December 4, 2025
2026 Annual Compliance Requirements for Health Plans
Employers that provide employee benefits to their employees are subject to numerous compliance requirements throughout the year, such as requirements for reporting, participant disclosure, and certain fee payments. For example, employers with group health plans may be required to:
- File Form 5500 by the last day of the seventh month following the end of the plan year—generally July 31—or request a filing extension by that date.
- Pay Patient-Centered Outcomes Research Institute (PCORI) fees by July 31 of each year.
- Provide Medicare Part D creditable coverage disclosures to plan participants by October 15 of each year.
- Provide Gag Clause attestation to CMS via its website by December 31 of each year.
This Compliance Calendar contains a high-level summary of the various compliance requirements and associated deadlines that health plan sponsors should be aware of throughout the year. It also summarizes annual notice requirements for group health plans. Please note that certain deadlines for non-calendar year plans may vary.
The calendar will note whether the specific date is based on the calendar year or the plan year.
This Legal Update is not intended to be exhaustive, nor should any discussion or opinion be construed as legal advice. Readers should contact legal counsel for legal advice. All rights reserved.
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