Odds are, you are planning 2026 with renewal reports and Open Enrollment meetings. Here are important tasks to keep on your radar for early 2026 that you don’t want to fall through the cracks.
Two Important Notes:
- The 2025 Form 5500 report, per the DOL, currently does not have any changes that affect the health and welfare side. As a result, you will be able to proceed with the Form 5500 preparation as normal.
- New this year is the new substance use of PHI requirement. See below under February.
| January | |||
| Optional 1 | Item | Deadline | |
| 1 | No | File Form 5500 for Plan year 7/1 | 1/31/26 |
| 2 | Yes | Line up CPA for trust plan IQPA report (audits typically can take 6 months) | 1/31/26 |
| February | |||
| Optional | Item | Deadline | |
| 1 | No | New substance use PHI requirements: Plans will need to deliver the entire updated NOPP (not just the availability of the NOPP) to participants in health care benefits. They also need to review their Business Associates Agreement with Third Parties and update the ones that will need the addition of the substance use PHI and resign. | “On or after” 2/16/2026 |
| 2 | No | ACA Information: Prepare reporting for IRS | 2/28/26 |
| 3 | No | File Form 5500 for Plan year 8/1 | 2/28/26 |
| 4 | Yes | Start collecting data for Form 5500 if the client has a 1/1 Plan year | 2/28/26 |
| 5 | No | If a calendar-year Plan had benefits taken away or reduced as of January 1, then the Summary Material Modification (SMM) is required to be distributed 60 days of the date of adoption. For some, the changes may have been relayed during open enrollment during the Fall of 2025. If not, they are required in the new year. | 2/28/26 |
| March | |||
| 1 | Yes | Determine if 5500s will be used for the PCORI Fee | 3/28/26 |
| 2 | No | File Form 5500 for Plan year 9/1 | 3/31/26 |
| 3 | No | 1094-C and copies of the Forms 1095-C (or 1094-B and 1095-B for self-insured non-ALEs) to the IRS | 3/31/26 |
| 4 | No | File 5500s that had the special extension up to Feb 2, 2026 | 3/3/26 |
| (applicable for States: TX, NM, and WV) | |||
| 5 | Yes | Determine if 5500s will be used for the PCORI Fee | 3/28/26 |
| 6 | No | File Form 5500 for Plan year 9/1 | 3/31/26 |
| 7 | No | 1094-C and copies of the Forms 1095-C (or 1094-B and 1095-B for self-insured non-ALEs) to the IRS | 3/31/26 |
| 1Optional is defined as the following: The item is not required by a specific date from an ERISA or DOL mandate. It is instead encouraged to help manage compliance requirements overall. | |||
If you have any questions or need to discuss, feel free to contact Ann McAdam at amcadam@wrangle5500.com.