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Year-End Benefits Guide · 2026

Don't let December sneak up on your benefits program.

Most year-end benefits problems are avoidable. This guide walks California employers through every deadline, limit change, and compliance obligation between now and December 31 — so you can close the year clean.

Q4
Highest-risk quarter for compliance misses
6
Key deadlines between Oct 1 and Dec 31
1.3%
CA SDI rate increase effective Jan 1, 2026
$0
Cost of a year-end review with Kim
Open Enrollment

The window is short. The decisions stick for 12 months.

Open enrollment is the one time each year employees can change their benefit elections without a qualifying life event. For calendar-year plans, open enrollment typically runs October through November, with January 1 effective dates. Here's what has to happen — and what commonly goes wrong.

  • Set your renewal date early — carriers typically release renewal rates 60–90 days before the plan anniversary. Do not wait for the carrier to prompt you.
  • Communicate rate changes clearly — employees need to understand what their new contributions will be before they make elections, not after.
  • Collect waivers in writing — employees declining coverage must sign a waiver. Keep this documentation. It matters at ACA audit time.
  • Update your HCM (Human Capital Management)/payroll — new elections must be loaded and confirmed before the first payroll of the new plan year. A missed update creates billing discrepancies that take months to untangle.
  • Confirm dependent documentation — if you require documentation for dependent enrollment (birth certificate, marriage certificate), collect it during open enrollment, not after.
  • Test your benefits portal — if you use an online enrollment platform, test it before you send employee communications. Platform issues during OE week are one of the most common year-end headaches we see.

Blue Ocean Benefits manages the entire open enrollment process for our clients — communications, employee questions, carrier submissions, and HCM (Human Capital Management) system updates. If your team is handling this manually, let's talk.

ACA Compliance

50+ employees? ACA reporting is not optional.

Applicable Large Employers (ALEs) — those with 50 or more full-time equivalent employees — must file IRS Forms 1094-C and 1095-C annually. The 2026 reporting cycle covers the 2025 plan year. Here's what you need to have in order by year-end.

  • Confirm your ALE status — count your full-time equivalent employees for 2025 now. If you crossed the 50 FTE threshold at any point during the year, you're an ALE for reporting purposes.
  • Verify affordability — for 2026 plan years, the ACA affordability threshold is 9.96% of employee household income (up from 9.02% in 2025). Run affordability calculations before your renewal is finalized.
  • Track offers of coverage monthly — you need to know which employees were offered coverage, what it cost, and whether they enrolled, for every month of the calendar year. If your payroll or HCM (Human Capital Management) system isn't capturing this, fix it now.
  • Prepare 1095-C forms — employees must receive their 1095-C by March 2, 2026. Electronic filing with the IRS is due March 31, 2026.
  • Document safe harbors — if you're relying on a W-2, Rate of Pay, or Federal Poverty Line safe harbor to establish affordability, document which one and ensure it's applied consistently.
Important

The penalty for failing to file or filing incorrect 1094-C/1095-C forms is $330 per return (2026 rate), with no cap for intentional disregard. If you're not sure whether your reporting is accurate, a pre-filing review is worth the time.

FSA / HSA / DCFSA

Employee account balances need attention before December 31.

Tax-advantaged accounts have different year-end rules depending on the account type. Getting this right — and communicating it clearly to employees — prevents forfeitures and employee complaints.

  • Health FSA — 2026 limit is $3,400 (up from $3,300 in 2025). Employees with unused balances face 'use it or lose it' rules unless your plan offers a grace period (up to 2.5 months) or a carryover (up to $680 for plans starting in 2026). Communicate deadlines clearly — most employees don't check their balance until January.
  • HSA — 2026 contribution limits: $4,400 for self-only coverage, $8,750 for family coverage (up from $4,300/$8,550). Unlike FSAs, HSA funds roll over indefinitely. Encourage employees to max out contributions before year-end if eligible.
  • Dependent Care FSA — 2026 limit is $7,500 per household ($3,750 if married filing separately). Funds must be used for qualifying childcare expenses incurred before December 31. Unused balances are forfeited unless a grace period applies.
  • Confirm your plan documents reflect 2026 limits — if your plan was established with a different limit, the plan document governs. A mismatch can create compliance issues.

New for 2026: ACA Bronze and Catastrophic marketplace plans are now HSA-eligible under IRS Notice 2026-5 (One Big Beautiful Bill Act). This may open HSA options for employees who were previously ineligible.

CalSavers

As of January 1, 2026, every California employer is covered.

The CalSavers phased rollout is complete. Every California private-sector employer with at least one W-2 employee must now either offer a qualified retirement plan or register for CalSavers. There is no size exemption anymore.

  • If you offer a 401(k), SIMPLE IRA, SEP-IRA, 403(b), or pension — submit a CalSavers exemption at employer.calsavers.com. Even if your plan is legitimate, you must formally register your exemption or you will receive penalty notices.
  • If you do not offer a qualified plan — register for CalSavers immediately at employer.calsavers.com. Add all eligible employees (age 18+, CA W-2 wages) within 30 days. New hires must be added within 30 days of their start date.
  • Default contribution rate is 5% of gross wages, automatically escalating 1% per year to 8% unless employees change their election. Employees can opt out.
  • Penalties: $250 per eligible employee after 90 days of noncompliance from the date of notice. $500 per employee after 180 days. Penalties compound.
  • New employers in 2026: If your business first reported having employees in 2026, your registration deadline is December 31, 2026.

If you're currently on CalSavers but want to evaluate whether a 401(k) would serve your team better — higher contribution limits, employer match, tax deductions — we work with payroll and retirement plan providers and can model the comparison.

State Disability Insurance

SDI rate increased to 1.3% for 2026.

California's SDI withholding rate increased from 1.2% to 1.3% effective January 1, 2026. This affects every California W-2 employee. Here's what to confirm before year-end.

  • Verify your payroll system updated to 1.3% on January 1, 2026 — if you've been processing payroll this year, your provider should have applied this automatically. Confirm in your payroll settings.
  • No wage cap — since January 1, 2024, SDI applies to all wages with no maximum. High earners will see meaningful deductions all year.
  • Maximum weekly SDI/PFL benefit for 2026 is $1,765 (up from $1,681 in 2025).
  • SDI covers both Disability Insurance (DI) and Paid Family Leave (PFL) — funded through the same employee payroll deduction.
  • Prepare for 2027 — the SDI rate is set annually by the EDD. Watch for the Q4 announcement and update your payroll system before January 1.

If you're on a PEO, your PEO is responsible for SDI withholding and remittance — but you should still verify. SDI errors on PEO-processed payroll can result in employee complaints and potential penalties.

Renewal Season

The worst time to evaluate your benefits is after you've already renewed.

Most employers receive a renewal offer from their carrier in Q4 and accept it without running an alternative market analysis. Here's why that's a problem — and what to do instead.

  • Get your renewal rates as early as possible — carriers are required to provide rates in advance. Push your broker to get renewal numbers 90 days out, not 30.
  • Run the full market — in California's employer market, every licensed broker accesses the same filed rates. The difference between staying and moving is plan design, network, and administration — not secret pricing.
  • Model total cost of ownership — premium is only part of the cost. Consider: employer contribution strategy, employee cost-sharing structure, plan utilization data, and administrative burden on your HR team.
  • Evaluate your contribution strategy — if your employer contribution hasn't been reviewed in 2+ years, you may be overpaying relative to market or underpaying relative to what it takes to attract employees in your sector.
  • Consider adding or removing voluntary benefits — year-end renewal is the right time to add supplemental benefits (critical illness, accident, hospital indemnity, legal, pet) or remove ones with low enrollment.

We run a full market analysis for every renewal — at no cost to the employer. If you're receiving a renewal quote from your current broker, let us see it before you sign. A second opinion costs nothing.

HR & Payroll

Benefits and payroll have to talk before December 31.

Year-end is when benefits and payroll systems get out of sync. Here's a coordination checklist to run before the calendar rolls.

  • Confirm W-2 box 12 codes — employer-sponsored health coverage costs must be reported in Box 12, Code DD on employees' W-2s. Verify your payroll system is capturing this correctly for all employees.
  • True up FSA/HSA contributions — confirm that what was elected matches what was actually withheld. Payroll errors during the year (leaves, terminations, mid-year changes) often leave discrepancies.
  • Process termination benefits correctly — terminated employees have COBRA rights. Ensure COBRA notices went out within 14 days of qualifying events throughout the year. Cal-COBRA applies to groups with 2–19 employees.
  • Audit your enrollment data — pull a report of who is enrolled in what, and cross-reference against your carrier invoices. Billing discrepancies compound over a plan year and are painful to unwind.
  • Update beneficiary designations — remind employees to review and update beneficiaries on life insurance and retirement accounts. This is often skipped at open enrollment and causes serious problems.
  • Archive your plan documents — keep copies of your Summary Plan Descriptions (SPDs), plan amendments, and wrap documents. ERISA requires that these be available to employees upon request.
Federal filings

Six federal filings CA employers miss most often

Beyond ACA reporting, these six filings apply to almost every group health plan — and they're the ones we see missed most often at year-end intake. Each links to the primary regulator.

Gag Clause Attestation

Annually by December 31

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

Attest to CMS that plan contracts contain no gag clauses restricting access to provider-specific cost or quality data. Required under the Consolidated Appropriations Act.

RxDC Reporting

Annually by June 1

All group health plans

Prescription drug and health care spending data submitted to CMS. Carrier typically files for fully-insured plans, but the employer is legally responsible — get written confirmation.

Mental Health Parity NQTL Comparative Analysis

On file at all times; produce within 10 days of DOL request

All group health plans covering mental health / substance use disorder benefits

Written comparative analysis of every non-quantitative treatment limitation (prior auth, network composition, medical necessity). Enforcement has intensified — most plans don't have one on file.

Form 5500

July 31 (calendar-year plans); extendable to Oct 15

Plans with 100+ participants on the first day of the plan year (health & welfare)

Annual return/report to the DOL. Small-plan exemption applies under 100 participants for most welfare plans. Late filing penalty is $2,739/day (2026), no cap.

PCORI Fee

July 31 (Form 720, Q2)

Self-funded plans, HRAs (including ICHRAs), and level-funded arrangements

$3.47 per covered life for plan years ending Oct 2024–Sep 2025; adjusted annually. Fully-insured employers: the carrier pays it, not you.

Medicare Part D Disclosure to CMS

Within 60 days of plan year start (Mar 1 for calendar-year plans)

All group health plans providing prescription drug coverage

Separate from the employee-facing Creditable Coverage notice — this one goes to CMS via online form. Missed constantly. Free, takes 5 minutes.

2026 IRS & ACA limits

2026 contribution limits & ACA thresholds at a glance

Every 2026 number you'll be asked about between now and April. Print it, tape it to your monitor, share it with payroll.

Item2026 limitNote
401(k) / 403(b) elective deferral$24,500Up from $23,500 in 2025
401(k) catch-up (age 50+)$8,000Standard catch-up
401(k) super catch-up (age 60–63)$11,250SECURE 2.0 enhanced catch-up
HSA — self-only$4,400Up from $4,300
HSA — family$8,750Up from $8,550
HSA catch-up (age 55+)$1,000Fixed by statute
HDHP minimum deductible$1,700 / $3,400Self-only / family
HDHP max out-of-pocket$8,500 / $17,000Self-only / family
Health FSA$3,400Carryover up to $680
Dependent Care FSA$7,500$3,750 MFS
Commuter benefits (transit / parking)$340 / monthEach, pre-tax
Adoption assistance$17,280Employer-provided, tax-free
ACA affordability threshold9.96%Of employee household income (ALEs 50+)
ACA employer mandate — no coverage penalty (§4980H(a))$3,180 / FT EEAnnual, per full-time employee
ACA employer mandate — unaffordable coverage (§4980H(b))$4,770 / FT EEPer FT EE receiving subsidy
1094-C / 1095-C late filing$330 / returnNo cap for intentional disregard
QSEHRA — self-only / family$6,450 / $13,100For eligible small employers

Sources: IRS Rev. Proc. 2025-32, IRS Notice 2025-46 (ACA affordability), IRS Rev. Proc. 2025-19 (HSA/HDHP). Not tax or legal advice — confirm application with your CPA or ERISA counsel.

2026 calendar

The 2026 benefits compliance calendar — date-sorted

Every deadline from this guide, in the order you'll hit them. Add these to your ops calendar the first week of January.

  • Feb 2, 2026W-2s and 1099s to employees & contractors (Jan 31 falls on a Saturday)
  • Feb 2, 2026Form 940 (FUTA) & Q4 Form 941 due (Jan 31 falls on a Saturday)
  • Mar 1, 2026Medicare Part D Disclosure to CMS (calendar-year plans)
  • Mar 2, 20261095-C forms to full-time employees
  • Mar 31, 20261094-C / 1095-C e-filed with IRS
  • Apr 30, 2026Q1 Form 941 due
  • May 13, 2026CA Pay Data Report to CRD (100+ CA employees)
  • Jun 1, 2026RxDC Reporting to CMS
  • Jul 31, 2026Form 5500 (calendar-year plans, 100+ participants)
  • Jul 31, 2026PCORI fee (Form 720) — self-funded & HRA plans
  • Sep 30, 2026Summary Annual Report (SAR) to participants
  • Oct 14, 2026Medicare Part D Creditable Coverage notice to Medicare-eligible employees
  • Oct 15, 2026Form 5500 extended deadline
  • Nov–Dec 2026Open enrollment window (calendar-year plans)
  • Dec 31, 2026Gag Clause Attestation to CMS
  • Dec 31, 2026New CA employer CalSavers registration deadline
California-only

California year-end items national guides skip

These CA obligations sit outside the federal checklist your carrier or national broker will hand you. Skip them and the penalty exposure is real.

CA Pay Data Reporting — due May 13, 2026

Private employers with 100+ employees (including 100+ workers hired through labor contractors) file 2025 pay data with the CA Civil Rights Department. Snapshot period is any pay period in Oct–Dec 2025. Penalties up to $200/employee.

I-9 self-audit before year-end

Pull a sample of I-9s and confirm Section 1, Section 2, and reverifications are complete. ICE audit penalties range from $288 to $2,861 per form (2026 adjusted). Correct errors in a different color ink with initials and date — never backdate.

Local minimum-wage & poster refresh

CA localities update their minimum wage on staggered schedules (Jan 1 or Jul 1). Refresh the CA IWC Wage Order, Wage Theft Prevention Notice, and any local posters (LA, SF, San Diego, WeHo) at every worksite.

Sick leave & PSL local ordinances

CA statewide is 40 hours/5 days accrual. LA, SF, San Diego, Berkeley, Emeryville, Santa Monica, Long Beach have higher local floors. Confirm your accrual and cap match the strictest applicable ordinance for each worksite.

EEO-1 Component 1 filing

Employers with 100+ employees (or 50+ federal contractors) file with EEOC in Q2 2026. Snapshot pay period Oct–Dec 2025. Confirm HRIS demographic data is clean before year-end.

CA Workplace Violence Prevention Plan

SB 553 requires a written WVPP, annual training, and an incident log. Refresh training records and confirm the log is up to date before your Cal/OSHA cycle.

2026 California minimum wage — state & local

Local ordinances override the state rate where higher. Verify each worksite. Local rates feed directly into ACA affordability if you use the Rate-of-Pay safe harbor.

LocalityRateEffective
California statewide$16.90 / hrJan 1, 2026
California — fast food$20.70 / hrJan 1, 2026 (AB 1228 CPI)
California — healthcare$18–$25 / hrBy facility type (SB 525)
Los Angeles (City)$17.87 / hrJul 1, 2025 (next bump Jul 1, 2026)
Los Angeles County (unincorp.)$17.81 / hrJul 1, 2025
San Francisco$19.18 / hrJul 1, 2025 (CPI bump Jul 1, 2026)
San Diego (City)$17.25 / hrJan 1, 2026
West Hollywood$19.65 / hrJul 1, 2025
Emeryville$19.90 / hrJul 1, 2025 (CPI bump Jul 1, 2026)
Berkeley$19.18 / hrJul 1, 2025 (CPI bump Jul 1, 2026)
FAQ

Year-end benefits — the questions we field on repeat

What's the difference between the Medicare Part D notice to employees and the disclosure to CMS?

The employee notice tells Medicare-eligible workers whether your Rx coverage is creditable — due by October 14 each year. The CMS disclosure is a separate online form telling CMS the same thing — due within 60 days of the plan year start (March 1 for calendar-year plans). Both are required. Most employers miss the CMS one.

Who has to file the Gag Clause Attestation?

Every group health plan — fully-insured and self-funded, regardless of size. The employer is legally responsible. Fully-insured carriers typically file on behalf of the plan, but get written confirmation. Due December 31 each year to CMS.

Do we need a Form 5500 for our health plan?

Only if the plan had 100 or more participants on the first day of the plan year (welfare plan small-plan exemption). A wrap document can combine medical, dental, vision, life, and disability into one 5500 filing. Under 100 participants: no filing required for unfunded/insured welfare plans.

We're fully insured. Do we owe the PCORI fee?

No — the carrier pays PCORI for fully-insured plans. But if you have an HRA (including ICHRA) or any self-funded component (e.g. self-funded dental), you owe PCORI on Form 720 by July 31 for those pieces. $3.47/covered life for plan years ending Oct 2024–Sep 2025.

What's the ACA affordability calculation for 2026?

The lowest-cost self-only plan you offer must not exceed 9.96% of the employee's household income (up from 9.02% in 2025). Most employers use one of three safe harbors: W-2 Box 1, Rate of Pay, or Federal Poverty Line. Apply the same safe harbor consistently to a reasonable category of employees.

Does the W-2 Box 12 DD requirement apply to us?

Only if you filed 250 or more W-2s in the prior calendar year. Smaller employers may report voluntarily but aren't required. If you cross 250 for 2025, you must report the aggregate cost of employer-sponsored health coverage in Box 12, Code DD on 2026 W-2s.

What happens if we miss the CalSavers registration deadline?

$250 per eligible employee after 90 days of noncompliance from the date of notice; $500 per employee after 180 days. Penalties compound and the CA Franchise Tax Board issues the notices. Even if you have a 401(k), you must formally register your exemption at employer.calsavers.com.

Do we have to give an employee their 1095-C if they weren't enrolled?

If they were full-time (30+ hours/week) for any month of 2025, yes — even if they waived coverage or weren't offered it. The 1095-C documents the offer (or non-offer) for ACA employer-mandate purposes. Only true part-time employees who were never full-time get skipped.

Work with us

A free year-end review. No cost. No obligation.

Every Q4, we offer a focused call for California employers who want an outside read on their benefits program before they renew. We look at your current plan, your renewal offer, your payroll setup, and your compliance posture — and give you a plain-language read on what's working and what isn't.

Renewal audit

We review your current plan, the renewal offer, and what the open market looks like. If there's a better option, we'll find it. If you're already well-positioned, we'll tell you that too.

Compliance check

We walk through your ACA status, CalSavers registration, FSA/HSA limits, and year-end deadlines. If something's out of order, better to know now.

Payroll coordination

We look at how your benefits connect to your payroll setup and flag any coordination issues before they become W-2 problems.

Free download

Download the Year-End Benefits Checklist.

A printable, one-page checklist covering every deadline and action item in this guide. Updated for 2026.

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