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🇺🇸 Federal Employer Compliance
2026 Federal HR Compliance Calendar
Our Federal HR Compliance Calendar is Federal specific employer compliance deadlines for 2026 — ACA 1094-C/1095-C reporting, Form 5500 filings, COBRA notices, ERISA plan administration, PCORI fees, Medicare Part D notices, open enrollment timing, and key IRS tax deadlines every employer needs to track.
40+
Federal Deadlines Tracked
$250
Per-Day 5500 Late Penalty
$340
ACA Per-Form Penalty (2026)
50+
FTE Threshold for ALE Status
📋 About This Federal Calendar
This calendar tracks federal employer HR and benefits compliance deadlines for calendar-year plans in 2026. Key coverage areas:
- ACA Reporting: 1094-C/1095-C furnishing and IRS filing deadlines for Applicable Large Employers (50+ FTEs).
- Form 5500: ERISA annual reporting for welfare benefit plans with 100+ participants and all qualified retirement plans. Late filing: $250/day up to $150,000.
- COBRA Notices: Qualifying event notices (30 days) and general initial notices (90 days from coverage start) — rolling year-round obligations.
- ERISA Plan Administration: SMMs, SARs, SPDs, CHIP notices, HIPAA Privacy, Medicare Part D creditable coverage, and safe harbor 401(k) notices.
- PCORI Fee: Annual fee on self-insured plans and HRAs filed via Form 720 by July 31.
- Open Enrollment: Key planning, materials, and carrier submission timelines for January 1 renewals.
- Tax / IRS: W-2, 1099, and key individual and corporate return deadlines.
âš Important: This calendar reflects federal deadlines as of January 2026 for calendar-year plans. Deadlines may shift based on your plan year, employer size, filing elections, and applicable IRS/DOL guidance. When a deadline falls on a weekend or federal holiday, it is typically extended to the next business day. Contact JS Benefits Group for guidance specific to your company.
January 2026
5 deadlines
Ongoing
All Year
COBRA Qualifying Event Notices
Employers must notify the plan within 30 days of a qualifying event. Plan administrator then has 14 days to notify COBRA qualified beneficiaries. Running deadline throughout the year.
COBRA
Jan 2
Friday
W-2 Forms Available to Employees (Electronic)
Employees who opted into electronic W-2 delivery should have access to 2025 W-2s. Payroll systems must have written consent on file.
Tax / IRS
Jan 31
Saturday
Form 1099-NEC / 1099-MISC Distribution
Furnish 1099-NEC to non-employee contractors paid $600+ in 2025. 1099-MISC for other reportable payments. Electronic filing required for 10+ returns.
Tax / IRS
Feb 2
Monday
W-2 Forms — Furnish to Employees 🔴 High Priority
Deadline to furnish W-2s to employees (Jan 31 falls on Saturday, deadline moves to next business day). Applies to all 2025 wages. Employers filing 10+ information returns must e-file.
Tax / IRS
Mar 2
Monday
ACA 1095-B / 1095-C — Furnish to Employees 🔴 High Priority
ALEs (50+ FTEs) must furnish 2025 Form 1095-C to all full-time employees. Self-insured employers of any size furnish 1095-B. Standard deadline is Jan 31, but IRS has historically granted a 30-day extension to March 2. Confirm current IRS guidance.
ACA
February 2026
3 deadlines
Feb 2
Monday
W-2 / W-3 Filing with SSA
Deadline to file W-2s and W-3 transmittal with the Social Security Administration. Employers with 10+ information returns must e-file. Paper filing permitted only under 10 forms.
Tax / IRS
Feb 2
Monday
Form 1099 E-File with IRS
1099-NEC and certain other 1099 forms must be filed with the IRS by this date. 1099-MISC has a later March e-file deadline.
Tax / IRS
Feb 28
Saturday
ACA 1094/1095 Paper Filing with IRS
Paper filing deadline for ACA transmittal forms — only permitted for employers filing fewer than 10 ACA returns. Most employers must e-file by March 31.
ACA
March 2026
4 deadlines
Mar 2
Monday
Medicare Part D Creditable Coverage Disclosure to CMS
Employers sponsoring prescription drug coverage must file online disclosure with CMS within 60 days of the start of the plan year (March 2, 2026 for January 1 plan year — March 1 falls on Sunday).
ERISA
Mar 16
Monday
FSA Grace Period Ends (2.5 Month Plans)
If your FSA plan uses a 2.5-month grace period (rather than the $660 rollover option), March 15 is the last day employees can incur claims against prior-year FSA funds. March 15 falls on Sunday — deadline moves to Monday March 16.
ERISA
Mar 31
Tuesday
ACA 1094-C / 1095-C E-File with IRS 🔴 Critical
ALEs (Applicable Large Employers, 50+ FTEs) must electronically file 2025 Forms 1094-C and 1095-C with the IRS. The 10-return e-file threshold applies. Late filing penalties are assessed per return.
ACA
Mar 31
Tuesday
CHIP Notice — Annual Distribution
Annual Children’s Health Insurance Program premium assistance notice must be sent to all employees residing in states with CHIP premium assistance. Best practice: distribute with open enrollment or annually in Q1.
ERISA
April 2026
3 deadlines
Apr 15
Wednesday
Individual / C-Corp Tax Return Deadline
Federal income tax deadline for individuals and C-corporations (calendar year). Also the deadline for prior-year IRA, HSA, and certain retirement contributions.
Tax / IRS
Apr 15
Wednesday
401(k) Excess Deferral Refund Deadline
Excess 401(k) deferrals above the annual limit must be distributed to employees by April 15 to avoid double taxation. Coordinate with payroll and plan administrator.
ERISA
Ongoing
90-Day Window
COBRA General (Initial) Notice — Ongoing
New employees and covered spouses must receive the COBRA General Notice within 90 days of coverage start. This is a rolling obligation — track all new enrollments and document delivery.
COBRA
May 2026
2 deadlines
May 15
Friday
Summary of Material Modifications (SMM) Check
If your plan was materially modified during 2025, an SMM must be distributed within 210 days after the end of the plan year in which the change occurred (for calendar-year plans, by July 29). Full SPD restatements are required every 5 years (10 for unchanged plans).
ERISA
May 31
Sunday
Annual Health Plan Notices — Review Cycle
Mid-year is a good checkpoint for annual participant notices: WHCRA (Women’s Health and Cancer Rights Act), Newborns’ Act, HIPAA Privacy, and Wellness Program notices. Many employers bundle these with open enrollment in the fall.
ERISA
June 2026
2 deadlines
Jun 30
Tuesday
FSA Claims Run-Out Period Ends (Typical)
If your FSA plan has a standard 90-day run-out period, June 30 is generally the deadline for employees to submit 2025 FSA claims for reimbursement. Check your specific plan document.
ERISA
Jun 30
Tuesday
Form 5500 Preparation — Begin
Calendar-year plans should begin Form 5500 preparation now. Large plans (100+ participants) require audited financials, which can take 6–8 weeks. Engage your auditor and TPA early.
Form 5500
July 2026
3 deadlines
Jul 31
Friday
PCORI Fee — IRS Form 720 Due 🔴 Annual
Patient-Centered Outcomes Research Institute fee due for self-insured group health plans and HRAs. Filed via IRS Form 720 Quarterly Federal Excise Tax Return. Applies per covered life for plan years ending in 2025. Fully-insured employers: the carrier pays the fee.
PCORI
Jul 31
Friday
Form 5500 — Calendar Year Plans 🔴 Critical
ERISA annual reporting due for welfare benefit plans (100+ participants) and all qualified retirement plans. File electronically via EFAST2. Small welfare plans (under 100 participants) that are fully-insured or unfunded are generally exempt. Late filing penalty: $250/day up to $150,000.
Form 5500
Jul 31
Friday
Form 5558 — Extension Request
File Form 5558 by the original Form 5500 due date to receive an automatic 2.5-month extension. Extended 5500 deadline becomes October 15, 2026. No reason required, but form must be submitted on time.
Form 5500
August 2026
2 deadlines
Aug – Sep
Planning Window
Open Enrollment — Renewal Planning Begins
Most calendar-year group health plans renew January 1. Employers should begin renewal negotiations, plan benchmarking, and employee communication planning 90–120 days before renewal. JS Benefits Group can help.
Open Enrollment
Aug 31
Monday
Medicare Part D Notice — Preparation
Annual notice of creditable or non-creditable prescription drug coverage must be provided to Medicare-eligible participants and covered family members before October 15 (Medicare enrollment period). Best practice: prepare notices in August for September distribution.
ERISA
September 2026
3 deadlines
Sep 30
Wednesday
Summary Annual Report (SAR) Distribution
For plans that filed Form 5500 by July 31 without extension, the SAR must be distributed to participants within 2 months of the filing deadline — by September 30. If your plan was extended to October 15, the SAR deadline extends accordingly.
ERISA
Sep 30
Wednesday
HIPAA Notice of Privacy Practices Review
Self-insured group health plans acting as HIPAA covered entities must provide an updated Notice of Privacy Practices at least once every 3 years, and following any material changes. Best practice: distribute annually with open enrollment materials.
ERISA
Sep – Oct
Action Window
Open Enrollment Materials Finalization
Employee communications, benefit guides, enrollment platform setup, and SBC (Summary of Benefits and Coverage) distribution should be completed before your OE window opens. SBCs must be provided automatically with enrollment materials.
Open Enrollment
October 2026
4 deadlines
Oct 14
Wednesday
Medicare Part D Notice — Annual Distribution 🔴 Hard Deadline
Must be provided to all Medicare-eligible employees and dependents BEFORE October 15 (Medicare’s open enrollment period). Required annually, regardless of whether coverage is creditable or non-creditable.
ERISA
Oct 15
Thursday
Form 5500 Extended Deadline 🔴 Final
Final deadline for calendar-year plans that filed Form 5558 for a 2.5-month extension. No further extensions permitted. Late filing penalty: $250/day up to $150,000 per plan; DOL penalties are separate.
Form 5500
Oct 15
Thursday
Medicare Annual Enrollment Period Opens
Medicare open enrollment runs October 15 through December 7. Employees eligible for Medicare should have received their creditable coverage disclosure before this date.
ERISA
Oct – Nov
OE Window
Open Enrollment Window (Typical for Jan 1 Renewal)
Most mid-size employers hold a 2–4 week open enrollment period in October or November for January 1 effective dates. ERISA requires adequate notice and access to plan documents during this period.
Open Enrollment
November 2026
3 deadlines
Nov 1
Sunday
ACA Marketplace Open Enrollment Opens
HealthCare.gov open enrollment period begins for individuals seeking 2027 coverage. Relevant for employers sponsoring ICHRA or QSEHRA plans, and for advising employees transitioning between employer and marketplace coverage.
ACA
Nov 30
Monday
Safe Harbor 401(k) & QDIA Notices — Prep Deadline
Safe harbor 401(k) and QDIA notices must be distributed at least 30 days (but not more than 90 days) before the plan year begins. For January 1 plan year, notices must be delivered by December 1 — finalize and begin distribution in November.
ERISA
Nov 30
Monday
Open Enrollment Closes (Typical)
Most employer OE periods close by November 30 for January 1 coverage. Final elections must be submitted to carriers, and enrollment files transmitted to ensure ID cards and coverage are in place by January 1.
Open Enrollment
December / Year-End 2026
4 deadlines
Dec 1
Tuesday
Safe Harbor / QDIA / Auto-Enrollment Notices 🔴 Hard Deadline
Annual safe harbor 401(k), QDIA, and automatic enrollment notices must be distributed at least 30 days before the start of the plan year (by December 1 for January 1 plan year). Late distribution can jeopardize safe harbor status.
ERISA
Dec 7
Monday
Medicare Annual Enrollment Period Closes
Medicare open enrollment ends December 7. By this date, Medicare-eligible employees should have received their creditable coverage disclosure and made any necessary election changes.
ERISA
Dec 15
Tuesday
ACA Marketplace Enrollment Deadline (Jan 1 Coverage)
Employees enrolling in HealthCare.gov marketplace coverage effective January 1, 2027 must enroll by December 15. Particularly relevant for ICHRA and QSEHRA plan sponsors whose employees use marketplace plans.
ACA
Dec 31
Thursday
FSA Funds Forfeiture (Use-It-or-Lose-It)
Calendar-year FSA plans with no grace period or rollover election forfeit unused funds at year end. Remind employees to submit claims and use remaining balances. Plans may allow up to $660 rollover (2026 indexed figure — confirm IRS update).
ERISA
📋 Federal Sources
Deadlines sourced from the following federal agencies:
- IRS (irs.gov)
- DOL / EBSA (dol.gov)
- HHS / CMS (cms.gov)
- SSA (ssa.gov)
- PCORI (pcori.org)
💡 From Jennifer Schaefer
Most compliance violations I see aren’t intentional — they’re missed deadlines. Build these dates into your payroll system or HR calendar now, and set 30-day reminders. We manage this for our clients so nothing falls through the cracks.
State-Specific Calendars
Federal Key Figures (2026)
IRS limits adjusted annually — verify at irs.gov before plan year begins.
Federal Agency Resources
The federal agencies and portals your HR and benefits teams need for 2026 compliance.
IRS
Internal Revenue Service
W-2/1099 filing, ACA 1094/1095-C reporting, PCORI Form 720, retirement plan limits, HSA/FSA contribution limits, and employer tax obligations at irs.gov.
DOL
DOL / EBSA
ERISA plan administration, Form 5500 filing via EFAST2, COBRA enforcement, HIPAA, CHIP notices, and employee benefits fiduciary standards at dol.gov/agencies/ebsa.
CMS
HHS / CMS
Medicare Part D creditable coverage disclosures, ACA marketplace rules, ICHRA and QSEHRA guidance, and employer coverage reporting at cms.gov.
SSA
Social Security Administration
W-2 and W-3 electronic filing via SSA Business Services Online, wage reporting, and Social Security coverage issues at ssa.gov/employer.
PCO
PCORI
Patient-Centered Outcomes Research Institute. Administers the annual PCORI fee on self-insured health plans and HRAs — paid via IRS Form 720 by July 31 each year.
Federal Benefits Compliance & HR Strategy
JS Benefits Group helps employers across PA, NJ, NY, MD, and DE navigate federal and state HR compliance — ACA reporting, Form 5500, COBRA administration, open enrollment, and group health plan design.
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Legal Disclaimer
The information on this page is for general informational purposes only and does not constitute legal, tax, or accounting advice. Deadlines and rates are subject to change. Consult qualified legal or accounting counsel before making compliance decisions specific to your organization. JS Benefits Group is not a law firm or accounting firm. Contact us for benefits and HR guidance specific to your company.
