2026 Compliance Checklist

Since its enactment in 2010, the Affordable Care Act (ACA) has introduced ongoing updates impacting employer-sponsored health plans, including annual adjustments to dollar limits, reporting requirements, and preventive care guidelines.

ACA requirements for employers sponsoring group health plans will change in 2026. Notably, the affordability threshold for applicable large employers (ALEs) will rise, allowing more flexibility when setting employee contribution rates.

Plan Design Changes

The following plan design requirements will change for 2026:

• Limits on cost sharing for essential health benefits;
• Coverage affordability percentage under the employer mandate rules; and
• First-dollar coverage for recommended preventive care items and services.

ACA Reporting Deadlines

• Employers must post a website notice by March 2, 2026, informing employees they may request an individual statement, or automatically provide statements by this date; and
• The deadline for electronic filing of 2025 ACA returns with the IRS is March 31, 2026.

Download the 2026 ACA Compliance Checklist for detailed information. Employers should review these ACA requirements and develop a clear compliance plan. Health plan documents including the Summary of Benefits and Coverage should be updated to reflect new plan limits, and ensure employees receive all relevant updates during open enrollment.