The 2026 Benefits & HR Compliance Calendar

New IRS limits & CA SDI rate take effect

All CA employers

Update payroll for 2026 limits: 401(k) $23,500, HSA $4,400/$8,750, FSA $3,400, DCFSA $5,000, ACA affordability 9.96%, CA SDI 1.3% (no wage cap).

CA statewide minimum wage → $16.90/hr

All CA employers

Update wage-theft prevention notices, IWC wage order posters, and any Rate-of-Pay ACA affordability calculations. Fast-food remains $20.70/hr; healthcare $18–$25 by facility type.

W-2s and 1099-NECs to recipients

All employers with W-2 employees; anyone paying $600+ to contractors

Furnish W-2s to employees and 1099-NECs to contractors. Also the IRS filing deadline for 1099-NEC (paper or electronic).

Form 940 (FUTA) & Q4 Form 941 due

All employers

Annual FUTA return and Q4 payroll tax return to IRS. If all deposits were made on time, Form 940 filing extends to Feb 10.

CA EDD DE 9 & DE 9C for Q4 2025

All CA employers

Quarterly Contribution Return (DE 9) and Quarterly Wage & Withholding Report (DE 9C) for Q4 2025 to CA EDD.

1099-MISC paper filing to IRS

Anyone who paid rent, royalties, prizes, medical/legal fees

Paper deadline for 1099-MISC (non-NEC). Electronic filers get until March 31.

Medicare Part D Disclosure to CMS

All plans with Rx coverage (calendar-year plans)

Online form to CMS confirming whether Rx coverage is creditable. Due within 60 days of plan year start. Most-missed federal filing we see.

HIPAA breach notice to HHS (breaches < 500)

Group health plans that had a <500-affected breach in 2025

Annual filing to HHS for any breach affecting fewer than 500 individuals during 2025.

1095-C forms to full-time employees

Applicable Large Employers (50+ FTE)

Furnish 1095-C to every employee who was full-time (30+ hrs/wk) for any month of 2025. Self-funded plans also issue 1095-B to enrolled non-FT.

401(k) ADP/ACP corrective distributions

401(k) plans that failed non-discrimination testing

Refund excess contributions to HCEs within 2.5 months after plan year-end to avoid 10% excise tax. Safe-harbor plans exempt from ADP/ACP.

1094-C / 1095-C e-filed with IRS

Applicable Large Employers (50+ FTE); mandatory e-file if 10+ returns

Electronic filing deadline for the 1094-C transmittal and all 1095-C returns via IRS AIR system.

1099-MISC electronic filing to IRS

Anyone who filed 1099-MISC electronically

Electronic filing deadline for 1099-MISC (non-NEC).

Q1 Form 941 & CA DE 9 / DE 9C due

All employers

Q1 2026 federal payroll tax return (941) and CA EDD quarterly filings (DE 9 / DE 9C).

SF Health Care Security Ordinance (HCSO) annual report

SF employers with 20+ worldwide employees (50+ for nonprofits)

Annual reporting to SF Office of Labor Standards Enforcement. Also confirm HCSO expenditure rate compliance for covered employees.

PCORI fee (Form 720, Q2) — first look

Self-funded plans, HRAs, ICHRAs, level-funded

Start pulling covered-life counts now for the July 31 Form 720 filing. $3.47/covered life for plan years ending Oct 2024–Sep 2025.

CA Pay Data Report to CRD

Private employers with 100+ CA employees (or 100+ labor contractors)

Snapshot pay period Oct–Dec 2025. Filed via CA Civil Rights Department portal. Penalties up to $200/employee for non-filers.

EEO-1 Component 1 filing (typical window)

Private employers with 100+ EEs; federal contractors 50+

Snapshot Oct–Dec 2025. EEOC opens the filing portal in Q2 and typically closes it in late May or early June. Exact date announced by EEOC each year.

RxDC Reporting to CMS

All group health plans (fully-insured & self-funded)

Prescription drug & health care spending data submitted to CMS. Carriers typically file for fully-insured; the employer stays legally responsible — get written confirmation.

Mid-year CA local minimum-wage bumps

Employers in LA, SF, Berkeley, Emeryville, WeHo, Pasadena, Santa Monica, more

Most CA local ordinances (LA City, LA County, SF, Berkeley, Emeryville, West Hollywood, Pasadena, Malibu, Santa Monica) escalate July 1 based on CPI. Verify each worksite.

Q2 Form 941 & CA DE 9 / DE 9C due

All employers

Q2 federal payroll tax return and CA EDD quarterly filings.

Form 5500 (calendar-year plans)

Welfare plans with 100+ participants on the first day of the plan year

Annual return/report to DOL. A wrap document can combine medical/dental/vision/life/disability into one filing. Extendable to Oct 15 via Form 5558. Late penalty $2,739/day, no cap.

PCORI fee filing (Form 720)

Self-funded plans, HRAs, ICHRAs, level-funded arrangements

$3.47 per covered life for plan years ending Oct 2024–Sep 2025. Fully-insured: your carrier pays it. If you have an HRA on top of an insured plan, you owe on the HRA piece.

Summary Annual Report (SAR) to participants

Any plan that files a Form 5500

SAR is due 9 months after plan year-end (calendar plans: Sep 30). Unfunded welfare plans that qualify for the exemption skip this.

Medicare Part D Creditable Coverage notice to employees

All plans with Rx coverage

Written notice to Medicare-eligible employees & dependents before the Medicare AEP begins Oct 15. Model notices published by CMS.

Form 5500 extended deadline

Plans that filed Form 5558 for an extension

Final deadline for extended 5500 filings.

Q3 Form 941 & CA DE 9 / DE 9C due

All employers

Q3 federal payroll tax return and CA EDD quarterly filings.

Open enrollment window opens (typical)

Calendar-year plans

Standard OE window is 2–3 weeks in Nov for a Jan 1 effective date. See our Open Enrollment Guide for the 90-day playbook.

401(k) Safe Harbor notice to participants

Safe-harbor 401(k) plans (calendar-year)

Annual safe-harbor notice must be furnished 30–90 days before the start of the plan year.

Gag Clause Attestation to CMS

All group health plans (fully-insured & self-funded)

Annual attestation via CMS HIOS portal that plan contracts don't contain gag clauses restricting cost/quality data. Confirm with your carrier who is filing.

New CA employer CalSavers registration deadline

CA employers that first had employees in 2026 & don't offer a qualified retirement plan

Register at employer.calsavers.com or file an exemption if you offer a 401(k)/SIMPLE/SEP/403(b). Penalties: $250/EE at 90 days, $500/EE at 180.

Section 125 plan document amendments effective

Employers changing cafeteria plan design for 2027

Any prospective plan change (new benefit, FSA carryover, DCFSA grace period, HSA eligibility) must be adopted in a written plan amendment by year-end.