As the new year approaches, employers can expect to face a busy start to 2026 filled with important compliance deadlines and regulatory requirements.
Staying informed and prepared helps to ensure timely filings, proper disclosures, and smooth benefits administration. This alert highlights the most important federal, state, and local deadlines for the first quarter of 2026, helping plan sponsors and HR teams proactively manage their responsibilities and avoid costly oversights.
We have separated our reminders into two categories: standard federal deadlines and select state and local deadlines. Within each category, we follow our typical chronological approach. Deadlines may or may not be applicable to your group, depending on employer and plan characteristics.
If you have any questions on the reporting and disclosure responsibilities below, please reach out to your Lockton account service team.
Here are potential action items for the first calendar quarter (through March 31, 2026).
STANDARD FEDERAL DEADLINES
Jan. 1 - Ensure medical plan ID cards reflect cost-sharing information (For calendar year plans; non-calendar year plans must distribute by the first day of the plan year)
Applies to all group medical plans (the obligation applies to non-calendar year plans as of the first day of the plan year beginning in 2022), but not excepted benefits such as most dental plans, most vision plans and most health flexible spending accounts (FSA).
The Consolidated Appropriations Act (CAA) requires group health plans to disclose, on any physical or electronic insurance identification card issued, the enrollee’s deductible and out-of-pocket maximums, and the telephone number and Internet website address where the enrollee may receive assistance.
For plan years beginning in 2022, employers may apply a good faith interpretation of the statutory requirement, absent additional federal guidance.
Jan. 1 - Distribute notice of grandfathered status (For calendar year plans; non-calendar year plans must distribute by the first day of the plan year)
Applies to ERISA and non-ERISA grandfathered plans subject to health reform.
Presumably, notice must be given to all participants no later than the first day of each plan year with respect to which the plan maintains grandfathered status. This is most often included in open enrollment or other plan materials supplied to participants.
Lockton has model notice language available upon request.
Jan. 1 - Price comparison tool
As part of the CAA and the Transparency in Coverage (TiC) final rules, the Departments of Labor, Health and Human Services, and Treasury issued a list of codes (opens a new window) for 500 items and services required to be included under the price comparison tool. The TiC rules include a requirement for plans and carriers to make available an Internet-based self-service tool to participants, beneficiaries and enrollees for price comparison purposes. The information also must be provided in paper form and by telephone if requested.
All coverage items and services must be available to search for plan years beginning on or after January 1, 2024.
Jan. 31 - Reflect imputed taxable income on Forms W-2
Imputed income might be an issue where health coverage is provided to non-dependent domestic partners and/or their children, or to an employee’s non-dependent adult, biological, step, adopted or foster child beyond the year the child attains age 26, or to other individuals with respect to whom coverage supplied to them is taxable to the employee, for federal tax purposes.
Health coverage supplied to a same-sex spouse is nontaxable (for federal tax purposes) to the employee.
Imputed income may also arise under group-term life insurance and some long-term disability programs.
Depending on state law, state income taxation may vary from federal taxation.
Jan. 31 - Report HSA contributions on Forms W-2
Employers report health savings account (HSA) contributions on employees’ Forms W-2 in Box 12, using code W. IRS instructions say to report “employer contributions” to HSAs but because the IRS views employee pretax payroll deductions as employer dollars, employers should also report employee pretax contributions to their HSAs if the contributions are made through payroll.
Jan. 31 - Report health plan coverage values on Forms W-2
W-2 reporting of health plan coverage values is merely informational and applies to employer sponsors of both grandfathered and non-grandfathered plans. This obligation applies with respect to reportable coverage, whether taxable or nontaxable.
Stand-alone dental and vision coverage, health reimbursement arrangement (HRA) contributions, and health FSAs funded solely by employee pretax contributions are exempt from this reporting requirement. Other exclusions also apply depending on the specific facts and circumstances.
Electronic filing to the IRS is required by those who file at least 10 returns under Code 6055.
Jan. 31 (or 30 days from request -whichever is later) - Upon request, disclose coverage offers to ACA full-time employees on Forms 1095-C, and/or self-insured coverage to primary insureds on Forms 1095-C or 1095-B (* This section applies if the Notice Method is used as described in the notes).
Applies to employers subject to the Affordable Care Act (ACA) employer mandate, and to smaller employers providing self-insured medical coverage to employees in the prior calendar year.
Beginning with the 2024 reporting year, employers may provide proper notice to individuals (Notice
Method) rather than distributing the 1095-C (or -B) to individuals. If the notice method is used and an individual requests their Form, the employer must provide it by the later of Jan. 31 of the year following the calendar year for which the return relates, or within 30 days of the request.
The employer must prominently note on its website that insureds may obtain the 1095-C or 1095-B on request, and must list a postal address, email address and phone number by which to request the form. States that require similar employer reporting, however, might not include this exception. See the state specific deadlines below.
Feb. 28 - Submit Forms 1094-C and/or 1095-B to IRS with Forms 1094-C or 1094-B (If filing paper forms; see entry below for March 31 if e-filing)
Employers must transmit copies of these forms to the IRS, with one or more Forms 1094-C or 1094-B transmittal documents.
The IRS requires e-filing of these forms if, when aggregating the number of these forms the employer must file with the number of W-2s, 1099s, and similar forms, the total is at least 10 starting with filing due dates falling in 2024 and beyond. The previous standard was at least 250 of the same form. Employers that obtained a waiver of the e-filing requirements must file paper forms by the deadline at left.
For more information on e-filing, see the March 31 deadline for e-filing below.
An automatic 30-day extension of time is available by filing Form 8809 on or before this due date.
March 1 - Submit annual notice of creditable and/or non-creditable coverage to Centers for Medicare and Medicaid Services (CMS) (For calendar year plans; non-calendar year plans must submit within 60 days following the first day of the plan year)
ERISA and non-ERISA plans must certify to CMS that prescription drug coverage offered under the plan is either Medicare Part D creditable or non-creditable.
The filing is made on the CMS.gov (opens a new window) website.
March 1 - File Form M-1 on behalf of multiple-employer welfare arrangements (MEWAs) and certain other arrangements
Applies to some MEWAs, as defined in ERISA, and some collectively bargained, multiple-employer programs.
An annual report (M-1) is not required if between Oct. 1 and Dec. 1 of the prior year the MEWA experienced an origination or special filing event and timely filed the M-1.
Some exceptions to Form M-1 filing apply. See Form M-1 and its instructions for more details.
March 2 - Report coverage offers to ACA full-time employees on Forms 1095-C, and/or self-insured coverage to primary insureds on Forms 1095-C or 1095-B (* This section applies if the Notice Method is not used as described previously above.)
Applies to employers subject to the ACA employer mandate, and to smaller employers providing self-insured medical coverage to employees, in the previous year.
The employer must provide a Form 1095-C with Parts I and II completed to each employee considered full-time (for ACA employer mandate purposes) for at least a month in the prior calendar year.
Self-insured employers must provide this Form, with Parts I and III completed, to each individual who had self-insured coverage for at least a day in the prior calendar year. Some employers will use Form 1095-B. Minor exceptions apply to this furnishing requirement with respect to individuals who at no time in the prior calendar year were ACA full-time employees. No extension to this deadline is available.
March 31 - E-file Forms 1095-C and/or 1095-B with IRS, with Form 1094-C and 1094-B (If e-filing; see entry above for Feb. 28 if filing paper forms)
Applies to employers providing to employees (or providing or making available to primary insureds) Forms 1095-C or 1095-B.
Employers providing to employees (or providing or making available to primary insureds) Forms 1095-C or 1095-B must transmit copies of these forms to the IRS, with one or more Forms 1094-C or 1094-B transmittal documents. The IRS requires e-filing of these forms if, when aggregating the number of these forms the employer must file with the number of W-2s, 1099s, and similar forms, the total is at least 10 starting with filing due dates falling in 2024 and beyond. The previous standard was at least 250 of the same form.
The employer may apply for a waiver of the e-filing requirement (if it prefers to file paper forms) on IRS Form 8508. However, if the waiver is granted, the employer must submit its paper forms by Feb. 28, subject to a potential 30-day extension of time via Form 8809.
E-filing is accomplished through the IRS’s AIR platform (opens a new window).
An automatic 30-day extension of time is available by filing Form 8809 before the due date.
March 31 - Distribute notice of Excepted Benefit Health Reimbursement Arrangement (EBHRA) (For non-federal government employees eligible for an EBHRA for the upcoming calendar year)
Applies to non-federal government group health plans.
Non-federal government employers that sponsor an EBHRA that reimburses eligible out-of-pocket 213(d) medical expenses must provide eligible employees notice about the EBHRA, the conditions of eligibility, the annual or lifetime caps or other limits on the benefits, and a summary of the benefits provided.
The annual notice deadline is no later than 90 days after the first day of the EBHRA plan year for employees who are eligible for an EBHRA.
SELECT STATE AND LOCAL DEADLINES
Jan. 1 (New Mexico) - Submit New Mexico Vaccine Purchasing Act quarterly covered lives assessment payment
The New Mexico Vaccine Purchasing Act (VPA) applies to fully insured plans and self-insured ERISA plans (including TPAs) covering children under age 19 who reside in New Mexico.
Jan. 1 (Massachusetts) - Submit Managed Care Organization (MCO) Payor Assessment monthly assessment fee
The Massachusetts Managed Care Organization (MCO) Payor Assessment applies to managed care organizations, including carriers and self-funded plans with Massachusetts members.
Jan. 2 (Vermont) - Submit Vermont Health Care Fund Contribution Assessment annual health care claims tax
The Health Care Claims Tax is an annual assessment on insurers and self-funded health plans to help fund Vermont’s health care initiatives. It applies to entities that pay for health care services for Vermont residents, including carriers and third-party administrators.
Jan. 25 (Vermont) - Submit Vermont Health Care Fund quarterly reporting and assessment payment for previous quarter
The HCFCA is a quarterly employer assessment designed to support Vermont’s health care programs. Employers with five or more full-time equivalent (FTE) employees in Vermont who do not offer health coverage to all employees may owe this assessment.
Jan. 30 (California) - Make San Francisco Healthcare Security Ordinance (HCSO) contributions for prior calendar quarter
For employers subject to the San Francisco HCSO. Quarterly contributions, if any, are due 30 days after the close of each calendar quarter.
See the end of February entry below for self-funded employers utilizing the annual true-up method.
Jan. 30 (Michigan) - Submit Michigan Insurance Provider Assessment Act quarterly assessment
Health insurers and certain managed care plans must pay quarterly assessments based on prior-year member months.
Jan. 30 (Rhode Island) - Submit Rhode Island Vaccine Assessment Program quarterly covered lives report and assessment
The Rhode Island Vaccine Assessment Program (RIVAP) requires certain health plans and payers to fund the state’s universal vaccine purchasing program through quarterly assessments based on covered lives.
Jan. 31 (Massachusetts) - Distribute Massachusetts Forms 1099-HC
Applies to employers that, in the prior calendar year, had employees in Massachusetts who had creditable coverage (as defined under Massachusetts state law) under the employer’s plan, and to the Massachusetts Department of Revenue. The disclosure is made to the employees.
Jan. 31 (California) (Unless deferred by state authorities) - Distribute Forms 1095-C to individuals who in the prior year were California residents and covered under the employer’s self-funded medical plan
Applies to employers who provided self-insured medical coverage to California residents in the prior calendar year.
Jan. 31 (Washington) - File Washington Cares (WA Cares) prior quarter report and remit payment of payroll tax withholdings
Applies to fully-insured and self-insured ERISA plans.
Feb. 1 (Connecticut) - Submit Connecticut Vaccine Program annual assessment
The Connecticut Vaccine Program (CVP) funds routine childhood immunizations by assessing insurers and TPAs that administer health benefit plans in the state. Applies to fully insured and self-insured ERISA plans (via TPAs and carriers licensed in Connecticut).
Feb. 2 (Massachusetts) - Submit Managed Care Organization (MCO) Payor Assessment monthly assessment fee
The Massachusetts Managed Care Organization (MCO) Payor Assessment applies to managed care organizations, including carriers and self-funded plans with Massachusetts members.
Feb. 15 (Alaska) - Report Alaska Vaccine Assessment covered lives
Employers and other assessable entities (health insurers, TPAs, self-funded ERISA plans) must report covered lives and vaccine usage data to the Alaska Vaccine Assessment Program (AVAP).
Feb. 15 (Maine) - Submit Maine Vaccine Board quarterly reporting and payment
Employers and health plans subject to Maine’s Vaccine Board childhood immunization assessment (health insurers, TPAs, self-funded employers) must report covered lives quarterly.
Feb. 15 (New Hampshire) - File New Hampshire Vaccine Association quarterly reporting and pay quarterly assessment fees
Health insurers, TPAs, and other assessable entities must report covered lives under age 19 and pay quarterly assessments via the New Hampshire Vaccine Association (NHVA) portal (opens a new window).
Feb. 15 (New Hampshire) - Report New Hampshire Health Plan (NHHP) covered lives and pay assessment fees
The New Hampshire Health Plan (NHHP) Assessment funds key state health initiatives. Health carriers, TPAs, and other assessable entities must report covered lives and pay quarterly assessments.
Feb. 15 (Vermont) - Submit Vermont Vaccine Purchasing Program reporting and assessment payment
The Vermont Vaccine Purchasing Program (VVPP) is Vermont’s universal vaccine program. It applies to health insurers, self-insured employers, TPAs, HMOs, and other entities that cover Vermont lives.
Feb. 15 (Washington) - Submit WAPAL Fund Q4 covered lives report and pay quarterly assessment
Applies to all assessed entities with covered lives in Washington, including Washington employers and out-of-state employers with covered lives in Washington. Applies to fully insured and self-insured ERISA plans.
Feb. 28 (California) - Make San Francisco Healthcare Security Ordinance expenditures due for prior year for covered employees in self-insured health plans
For employers subject to the San Francisco HCSO. Employers using the annual method for determining the adequacy of healthcare expenditures have until the last day of February to make any required true-up contributions for the prior year.
Feb. 28 (California) - Distribute employee healthcare payment confirmation on employee’s behalf to Healthy San Francisco
Applies to employers subject to the San Francisco Healthcare Security Ordinance, who satisfy the obligations of the ordinance by making contributions to the city, on behalf of covered employees.
March 2 (New Jersey) - Distribute coverage statements to individuals who in the prior year wereNew Jersey residents and covered under the employer’s self-insured medical plan
Applies to employers who provided self-insured medical coverage to New Jersey residents in the prior calendar year.
March 2 (D.C.) - Distribute coverage statements to individuals who in the prior year were District of Columbia residents and covered under the employer’s medical plan
District of Columbia individual mandate disclosures
Applies to employers who provided medical coverage to District residents in the prior calendar year.
March 2 (Rhode Island) - Distribute coverage statements to individuals who in the prior year were Rhode Island residents and covered under the employer’s medical plan
Applies to employers who provided self-insured medical coverage to Rhode Island residents in the prior year.
March 2 (Massachusetts) - Submit Managed Care Organization (MCO) Payor Assessment monthly assessment fee
The Massachusetts Managed Care Organization (MCO) Payor Assessment applies to managed care organizations, including carriers and self-funded plans with Massachusetts members.
March 15 (Idaho) - Report the number of program-eligible children covered as of January 31 under the Idaho Vaccine Assessment Program to the Idaho Department of Insurance
Applies to fully insured and self-insured ERISA plans (via carriers, TPAs, and plan sponsors operating in Idaho).
March 31 (California) - Submit Forms 1095-C and/or 1095-B, with Form 1094-C or 1094-B, to the California Franchise Tax Board
Applies to employers who provided medical coverage to California residents in the prior calendar year.
March 31 (Massachusetts) - Submit coverage statements (Forms 1099-HC) to the Massachusetts Department of Revenue
Massachusetts individual mandate reporting
Applies to employers who provided self-insured creditable coverage (under Massachusetts law) to employees in the prior calendar year.
March 31 (New Jersey) - Submit coverage statements to the New Jersey Division of Revenue and Enterprise Services
Applies to employers who provided medical coverage to New Jersey residents in the prior calendar year.
March 31 (Rhode Island - Deferred by state authorities from Jan. 31) - Submit coverage statements to the Rhode Island Department of Revenue, Division of Taxation
Applies to employers who provided medical coverage to Rhode Island residents in the prior calendar year.
Not legal advice: Nothing in this alert should be construed as legal advice. Lockton may not be considered your legal counsel, and communications with Lockton's Compliance Consulting group are not privileged under the attorney-client privilege.
For more alerts, insights and additional information, click here (opens a new window) to visit Lockton's ERISA Compliance Consulting page.
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