2026 Employee Benefits Market Outlook 5 Top Health Plan Compliance Issues for 2026 Employers should pay close attention to the key com- pliance issues that could affect how health plans are designed and administered in 2026. For example, beginning in 2026, many employers subject to reporting under the ACA will first take advantage of the simplified method for providing individual state-ments. Beyond that, several expected developments deserve monitoring, including possible updates to fed-eral mental health parity rules and related enforcement measures. Overall, the compliance landscape is marked by uncertainty, due to new regulatory priorities under the Trump administration, ongoing benefits-related litigation, and changes in federal staffing. This year, fed- eral agencies are balancing the rollout of the OBBBA with President Donald Trumps broader directives, including efforts to increase health care transparency. However, the pace and scope of regulatory activity may be constrained by federal budgetary limitations and staffing challenges. As employers consider the following key health plan compliance issues for 2026, they should evaluate how these developments could influence the structure and management of their health benefits going forward. Simplified ACA Reporting At the end of 2024, Congress passed legislation that eased ACA reporting requirements for employers. The ACA requires applicable large employers (ALEs) and non-ALEs with self-insured health plans to provide information to the IRS about the health plan coverage they offer (or do not offer) to their employees while providing related statements to individuals. Yet, with the new legislation, employers that take certain steps no longer need to automatically distribute these individual statements, unless an individual specifically requests one. In late February 2025, the IRS released guidance on this relief, leaving employers only a brief period to apply the change for statements due in March 2025. Because of the limited time frame, many employers are expected to begin using this relief starting in 2026. For this relief to apply in 2026, an employer must post a clear and conspicuous notice on its website by March 2, 2026, stating that employees may receive a copy of their statement upon request. The notice must include an email address, a physical address to which a request may be sent and a telephone number to contact the employer. This website notice must remain posted through Oct. 15, 2026. In general, employers must fulfill requests within 30 days of receiving them. Crossroads for Mental Health Parity Rules In May 2025, federal agencies announced they would not enforce a 2024 final rule that expanded parity requirements for mental health and substance use dis- order (MH/SUD) benefits. This decision stems from a lawsuit filed by an employer trade group challenging the rules validity. The case has been put on hold while the Trump administration reviews the rule and con- siders whether to revise or repeal it. Many of the final rules provisions were originally set to take effect in 2026. At the same time, the Trump administra- tion is taking a broader look at its overall approach to enforcing mental health parity. The Mental Health Parity and Addiction Equity Act (MHPAEA) requires parity between a group health plans medical/surgical (M/S) benefits and MH/SUD benefits. Notably, MHPAEA requires health plans and health insurance issuers to conduct comparative