2027 Group Health Plan Compliance: Planning Tips for Employers and Q1 Key Deadlines

For employers that sponsor group health plans, staying on top of compliance requirements is an ongoing responsibility. Annual reporting obligations, participant disclosures, and filing deadlines can create challenges for HR and benefits teams, particularly when requirements vary based on employer size, plan type, and other factors.

As 2027 approaches, now is a good time to review upcoming obligations, identify important deadlines, and coordinate with the teams responsible for managing them.

Before closing out 2026, employers may also want to review any remaining filing and disclosure requirements that apply to their plans for the current year. Acrisure^®'s 2026 Group Health Plan Compliance Calendar can serve as a reference for identifying year-end deadlines.

To help employers prepare for the coming year, Acrisure has developed a 2027 Group Health Plan Compliance Calendar outlining key federal filing and disclosure requirements throughout the year.

Key Takeaways

• Employers that sponsor group health plans may be subject to annual federal reporting, filing, and disclosure requirements.
• Key first-quarter 2027 deadlines include Form W-2 health coverage reporting, Medicare Part D disclosures, and Affordable Care Act (ACA) reporting.
• Compliance obligations can vary based on employer size, plan funding arrangement, and plan year.
• Reviewing requirements and assigning responsibilities before deadlines approach can help employers manage their compliance obligations.
• Acrisure’s 2027 Group Health Plan Compliance Calendar provides a reference for tracking important federal deadlines throughout the year.

What Are the Key Group Health Plan Compliance Deadlines for 2027?

Several important group health plan compliance deadlines occur during the first quarter of 2027. Employers should review which requirements apply to their plans and begin preparing the necessary information in advance.

^{The information below is for general informational purposes only. Deadlines are based on guidance available as of October 19, 2026 and are subject to change. Employers should confirm current deadlines with the IRS, CMS, or a qualified professional regarding their specific obligations.}

February 1, 2027: Form W-2 Health Coverage Reporting

Employers that filed 250 or more Forms W-2 in the prior year generally must report the cost of applicable employer-sponsored health coverage on employees' Forms W-2. Per IRS guidance, the usual January 31 deadline falls on a Sunday in 2027, moving the deadline to February 1.

March 1, 2027: Medicare Part D Disclosure to CMS

Group health plan sponsors offering prescription drug coverage generally must disclose to the Centers for Medicare & Medicaid Services (CMS) whether their coverage is creditable, meaning it is expected to pay, on average, at least as much as standard Medicare Part D coverage. Under CMS creditable coverage disclosure guidance, this annual disclosure is generally due within 60 days after the start of the plan year.

March 2, 2027: Forms 1095-B and/or 1095-C Furnishing Requirements

Applicable Large Employers (ALEs), generally those with 50 or more full-time employees, including full-time equivalents, and sponsors of self-insured health plans must satisfy applicable ACA reporting and furnishing requirements. Forms may be furnished directly or made available upon request when applicable notice requirements are met.

March 31, 2027: Electronic ACA Reporting to the IRS

ALEs and sponsors of self-insured health coverage generally must file applicable Forms 1094-B/C and 1095-B/C with the IRS, as described in the IRS Instructions for Forms 1094-C and 1095-C. Employers filing 10 or more information returns in total generally must file electronically. Employers permitted to file on paper are generally subject to an earlier March 1 deadline.

These dates represent only a portion of the federal requirements employers may need to address during 2027.

Download Acrisure’s 2027 Group Health Plan Compliance Calendar for additional deadlines, descriptions, and information about which plans and employers may be subject to each requirement.

How Can Employers Prepare for Group Health Plan Compliance in 2027?

A proactive approach to employee benefits compliance can help employers organize responsibilities, gather necessary information, and prepare for reporting and disclosure requirements.

The following steps can help HR and benefits teams plan for the year ahead.

1. Review Which Requirements Apply to Your Plans

Some compliance requirements apply only to certain employers or group health plans.

Factors such as the number of employees, whether a plan is fully insured (coverage is purchased from an insurance carrier) or self-insured, and whether it operates on a calendar-year or non-calendar-year basis can affect an employer’s obligations.

Reviewing these details can help identify which deadlines and disclosures deserve attention.

2. Establish a Compliance Calendar

A centralized calendar can help employers track upcoming filing and disclosure deadlines throughout the year.

Consider including internal preparation deadlines ahead of required submission dates. This gives time to gather information, review documentation, and address potential questions before a filing is due.

3. Coordinate Across Internal Teams and External Partners

Group health plan compliance often involves more than the HR or benefits department.

Payroll, finance, legal, and other teams may have responsibilities related to reporting, employee information, or required disclosures. Insurance carriers, third-party administrators, and other service providers may also support certain activities.

Clarifying who is responsible for each task can help reduce confusion and support timely completion.

4. Review Reporting Information and Documentation

Accurate information is important for meeting annual reporting obligations.

Employers can use the months leading up to filing deadlines to review relevant employee and coverage records, confirm reporting processes, and coordinate with vendors responsible for preparing or submitting forms.

Maintaining documentation of completed filings and disclosures can also support ongoing compliance efforts.

5. Stay Informed About Regulatory Changes

Group health plan compliance requirements can change as federal agencies issue new regulations, guidance, or reporting instructions.

Employers should monitor applicable updates throughout the year rather than relying exclusively on deadlines established at the beginning of the plan year.

Working with qualified legal, tax, and employee benefits professionals can help employers understand how requirements apply to their particular circumstances.

Plan Ahead with Acrisure’s 2027 Group Health Plan Compliance Calendar

Preparing for group health plan compliance doesn’t have to start when a deadline approaches.

Acrisure’s 2027 Group Health Plan Compliance Calendar brings together key federal filing and disclosure deadlines in one resource to help employers organize their compliance planning.

The calendar includes important dates, descriptions of applicable requirements, and information about which employers and plans may be affected.

Download the 2027 Group Health Plan Compliance Calendar

Have questions about group health plan compliance requirements or employee benefits planning? To learn more about how Acrisure can help support your organization’s employee benefits planning, contact an Acrisure representative.

^{IMPORTANT NOTICE: The opinions and statements herein are intended for general informational purposes only and should not be viewed as a substitute for any legal, regulatory or other advice on any particular issue or for any particular reason. The advice of a professional should always be obtained before purchasing any insurance product or service, and you should not rely on the information provided herein for the prevention or mitigation of risks or as a full and complete explanation of coverage under any insurance policy or as a full and complete explanation of terms and conditions of any products or services offered. While the information provided herein has been compiled from sources that are believed to be reliable, no warranty, guarantee or representation, either expressed or implied, is made as to the correctness, sufficiency, or adequacy of such information.}