December 2025 Sun Mon Tue Wed Thu Fri Sat 15 Provide SAR to Plan Participants need to provide an attestation. Employers with self- A (Calendar-Year Plans Only) if Form insured health plans can enter into written agreements 5500 Deadline Was Extended with their TPAs to provide the attestation, but the legal responsibility remains with the health plan. Provide an SAR to covered employees by Dec. 15, 2025, if you have a calendar-year plan and the plan’s form 5500 Compliance Reminders deadline was extended. In general, the SAR must be As 2025 comes to a close, review your company’s provided within nine months of the close of the plan year. compliance to ensure that all required activities will be However, if the plan’s Form 5500 deadline is extended, the completed by the end of the year. This review may include SAR must be provided within two months after the close of the following tasks: the extension period. For calendar-year plans, this extended deadline is Dec. 15, 2025. Plans that are exempt • Complete any outstanding annual performance reviews; from the annual 5500 filing requirement are not required to provide an SAR. Unfunded welfare plans are also generally • Confirm that any required workplace employee training will exempt from the SAR requirement. be completed by the appropriate deadline; • Encourage employees to fill out a new Form W-4 for 2026 if they have experienced personal or financial changes B Submit a Gag Clause Attestation that impact their tax withholding; and Employer-sponsored health plans and health insurance issuers must submit attestations of compliance • Confirm that annual nondiscrimination testing has been with the prohibition on gag clauses by Dec. 31 each year. performed for employee benefit plans that are subject to Plans and issuers can submit their attestations through a these testing requirements, including Section 125 CMS website. If the issuer for a fully-insured health plan cafeteria plans, self-insured health plans, health FSAs, provides the attestation, the health plan does not also dependent care FSAs, HRAs, group term life insurance and retirement plans.