Summary Annual Report Due Date: What Employers Need To Know For Plan Compliance
Calendar year plans face a Sept. 30 deadline to distribute SARs to participants. Here's what the requirement covers and how to stay ahead of it.
Many employers that must file Form 5500 on behalf of their employee benefit plans also have to provide plan participants with a summary annual report (SAR), a plain-language summary of the information included in that filing. For employers with calendar year plans, the summary annual report due date is Sept. 30, 2026. If the employer received an extension to file its Form 5500, the SAR deadline moves to Dec. 15, 2026.
Missing this deadline is one of the more common, and more avoidable, plan compliance gaps employers run into each fall. Here's a breakdown of the SAR requirements, what the notice must include, and how to keep your distribution on schedule.
Who The SAR Requirement Applies To
Each year, employers subject to the Employee Retirement Income Security Act (ERISA) must file an annual report, Form 5500, with the Department of Labor (DOL) for their employee benefit plans, unless a reporting exemption applies. Employers must also give plan participants a free summary of that filing every year.
A few exceptions are worth flagging:
If a plan is exempt from Form 5500 reporting, it's automatically exempt from the SAR requirement too.
Self-insured welfare plans, regardless of size, don't need to provide a SAR if they're unfunded, meaning benefits are paid directly from the employer's general assets rather than through a trust or separately maintained fund.
Large unfunded welfare plans with 100 or more covered participants must still file Form 5500, but they're exempt from providing a SAR.
What The SAR Must Include
The SAR only needs to cover information that was already required on the plan's Form 5500. In general, it must include the following.
Funding and insurance information. For uninsured plans, the SAR must state the types of claims the plan sponsor is committed to pay. For insured plans, it must state the types of claims covered under the insurance contract, along with the insurer's name and the annual premium paid.
Basic financial information. If plan assets are held in trust or a separately maintained fund, the SAR should show the value of plan assets at the start and end of the plan year, the increase or decrease in net assets, and total income and expenses for the year.
Rights to additional information. A statement telling participants they have the right to request a full copy of the Form 5500.
Offer of assistance in a non-English language. This applies to large plans (more than 100 participants) where the lesser of 10% or 500 or more participants are literate only in the same non-English language, and to small plans (fewer than 100 participants) where 25% or more of participants fall into that category.
The DOL has released a model SAR that employers can customize for their own plans.
Deadlines & Extensions
The SAR must go out within nine months of the close of the plan year. For calendar year plans, that lands on Sept. 30. Employers can request a two-and-a-half-month filing extension for Form 5500 by submitting IRS Form 5558. If that extension is granted, the SAR must be provided within two months of the close of the extension period, pushing the calendar year deadline to Dec. 15.
How SARs Can Be Distributed
SARs can be distributed using any method that's acceptable for summary plan descriptions, including:
Hand delivery to employees at their worksite
U.S. mail
Electronic delivery, if certain conditions are met
Rules for Electronic Delivery
DOL regulations include a safe harbor allowing employers to distribute certain ERISA-required documents, including the SAR, electronically to employees with work-related computer access and to other participants who consent to electronic delivery. To satisfy the safe harbor, employers must notify participants each time a disclosure is delivered electronically and take steps to confirm actual receipt.
A July 2026 proposed rule would create an additional, optional electronic delivery safe harbor specifically for group health plans, allowing broader use of website posting paired with a notice of availability. Until that rule is finalized, plan administrators should continue following the existing electronic delivery requirements.
Plan compliance deadlines like the SAR due date are easy to lose track of amid everything else on an employer's plate. Contact The Siekmann Company today to make sure your plan's reporting and disclosure obligations are on track.
Frequently Asked Questions
When is the summary annual report due date for 2026?
For calendar year plans, the SAR is due Sept. 30, 2026. If the employer filed IRS Form 5558 to extend its Form 5500 deadline, the SAR deadline extends to Dec. 15, 2026.
Do all employer plans have to provide a SAR?
No. Only plans required to file Form 5500 have a SAR requirement, and unfunded self-insured welfare plans are exempt regardless of size.
What happens if a plan misses the SAR deadline?
Missing the deadline is a plan compliance failure under ERISA and can expose the plan sponsor to DOL enforcement action, including penalties, so employers should treat the SAR deadline with the same urgency as the Form 5500 filing itself.
