Compliance
The Compliance Calendar, By Headcount
What applies at 20, 50 and 100 employees — and the handful of filings and notices that trip up small groups.
| Requirement | Threshold | What it means |
|---|---|---|
| COBRA | 20+ employees | Continuation coverage offers and notices after qualifying events (state mini-COBRA below 20 in many states) |
| Medicare Secondary Payer | 20+ employees | Group plan pays primary for active employees 65+ |
| Employer mandate (§4980H) | 50+ FTEs | Offer affordable, minimum-value coverage or face $3,780 / $5,670 penalties in 2027; Forms 1094-C / 1095-C |
| Form 5500 | 100+ participants (welfare plans) | Annual return for larger plans; small insured plans are generally exempt |
| Section 125 testing | Any plan | Annual nondiscrimination testing; plan document on file |
| ERISA SPD / notices | Any plan | Summary plan description, SBC, CHIP, WHCRA, Medicare Part D creditable-coverage notices |
General guidance from federal statutes and agency instructions as of Oct 2026; thresholds and state rules vary. Confirm with counsel or your administrator for your group.