Employers must comply with numerous reporting and disclosure requirements regarding their group health plans throughout the year. This Compliance Overview identifies key 2025 compliance deadlines for employer-sponsored group health plans and outlines the group health plan notices employers must provide each year.
Some compliance deadlines summarized below are tied to a group health plan’s plan year. For these requirements, the chart below shows the deadline that applies to calendar-year plans. For noncalendar-year plans, these deadlines will need to be adjusted to reflect each plan’s specific plan year.
Determining the Plan Year
The “plan year” is the calendar, policy or fiscal year on which the records of the plan are kept. Many employers operate their group health plans on a calendar-year basis from Jan. 1 through Dec. 31 of each year. Other employers operate their plans on a noncalendar-year basis, which may be consistent with the company’s taxable year or with an insured plan’s policy year.
For a full description, download the PDF file here.
January
- January 31, 2025: Report health plan costs on Form W-2 for employers who filed 250+ Forms W-2 in the prior year.
February
- February 28, 2025: Paper filing deadline for ACA Forms 1094-C/1095-C (ALEs) and 1094-B/1095-B (non-ALEs with self-insured health plans). Note: Most must file electronically by March 31.
March
- March 1, 2025: Medicare Part D disclosure to CMS for calendar-year plans.
- March 3, 2025: Furnish ACA Forms 1095-C (ALEs) and 1095-B (non-ALEs with self-insured health plans) to employees.
- March 31, 2025: Electronic filing deadline for ACA Forms 1094-C/1095-C and 1094-B/1095-B.
June
- June 1, 2025: Submit Prescription Drug Data Collection (RxDC) report covering 2024 data.
July
- July 31, 2025:
- Report and pay PCORI fees using IRS Form 720.
- File Form 5500 for calendar-year ERISA-covered plans (regular deadline).
September
- September 30, 2025:
- Watch for Medical Loss Ratio (MLR) rebates for fully insured plans.
- Provide a Summary Annual Report (SAR) for calendar-year plans subject to Form 5500.
October
- October 3, 2025: Provide Individual Coverage Health Reimbursement Arrangement (ICHRA) notices for 2026 plan year.
- October 14, 2025: Notify Medicare Part D-eligible individuals about prescription drug coverage (creditable/noncreditable).
- October 15, 2025: Extended filing deadline for Form 5500.
December
- December 15, 2025: Extended deadline to provide SAR for calendar-year plans that obtained Form 5500 extension.
- December 31, 2025: Submit gag clause attestation to comply with transparency requirements.
This timeline ensures employers are prepared to meet their compliance obligations throughout the year.
For a full description, download the PDF file here.
