Compliance Calendar
Forms W-2 and 1099-MISC Distribution Deadline
The deadline for providing W-2 forms to employees and 1099-MISC forms to other workers is January 31, 2025.
Form 941 Filing Deadline (fourth quarter)
File Form 941, Employer’s Quarterly Federal Tax Return for the fourth quarter of 2024. Deposit or pay any undeposited tax under the accuracy of deposit rules. If your tax liability is less than $2,500, you can pay it in full with a timely filed return. If you deposited the tax for the quarter timely, properly, and in full, you have until February 10 to file the return.
Form 940 Filing Deadline
The due date for filing Form 940, Employer’s Annual Federal Unemployment Tax Return for 2024 is January 31, 2025. However, if you deposited all your FUTA tax when it was due, you may file Form 940 by February 10, 2025.
Forms W-2 and W-3 Filing Deadline
The deadline for filing Copy A of Forms W-2 and W-3 with the Social Security Administration (SSA) is January 31, 2025. This deadline is for both paper and electronic filings.
Deadline for Posting OSHA Form 300A
Employers are required to post OSHA Form 300A, Summary of Work-Related Injuries and Illnesses, from February 1 – April 30. The summary must be displayed each year between February 1 and April 30 in a common area where notices to employees are usually posted.
Forms 1094-B, 1095-B, 1094-C and 1095-C Filing Deadline (paper filers)
If you are an applicable large employer (ALE) using paper filing, file Form 1094-C, Transmittal of Employer Provided Health Insurance Offer and Coverage Information Returns, and Forms 1095-C, Employer-Provided Health Insurance Offer and Coverage with the IRS. If you are a non-ALE provider of minimum essential coverage, file paper Form 1094-B, Transmittal of Health Coverage Information Returns, and Forms 1095-B, Health Coverage with the IRS. Note: Paper filing is only available to employers with fewer than 10 aggregated information returns. The due date for electronic filers is March 31, 2025.
Deadline to Submit Form 300A Data to OSHA
The following establishments must electronically submit their Form 300A data to OSHA via the agency’s Injury Tracking Application (ITA) by March 2nd of the year after the calendar year covered by the form.
- Establishments that had a peak employment of 100 or more employees during the previous calendar.
- The designated industries are listed in Appendix B to Subpart E of 29 C.F.R. Part 1904.
The requirements apply to establishments covered by Federal OSHA, as well as establishments covered by states with their own occupational safety and health programs (i.e., State Plans).
Deadline to Distribute Forms 1095-B and 1095-C
The deadline for furnishing Form 1095-B, Health Coverage, or Form 1095-C, Employer Provided Health Insurance Offer and Coverage to individuals is March 3, 2025 for tax year 2025.
Medicare Part D Creditable Coverage Disclosure Deadline (Calendar Year Plans Only)
Employers with group health plans providing prescription drug coverage to individuals that are eligible for Medicare Part D must disclose to CMS whether the coverage is “creditable prescription drug coverage”. This information must be provided electronically via the Disclosure to CMS form through the CMS website. See the CMS instruction guide for completing the form online. The form must be provided annually, within 60 days after the first day of the plan year for the reporting year. (March 3, 2025, for plan years beginning January 1, 2025)
Forms 1094-B, 1095-B, 1094-C and 1095-C Filing Deadline (electronic filers)
If you’re an applicable large employer (ALE), file electronic Form 1094-C, Transmittal of Employer-Provided Health Insurance Offer and Coverage Information Returns and Forms 1095-C, Employer-Provided Health Insurance Offer and Coverage with the IRS. If you are a non-ALE provider of minimum essential coverage, file electronic Form 1094-B, Transmittal of Health Coverage Information Returns and Forms 1095-B, Health Coverage with the IRS. The electronic filing deadline is March 31, 2025.
Note: Electronic filing is required for employers with 10 or more aggregated information returns.
Form 941 Filing Deadline (first quarter)
Deadline for filing Form 941, Employer’s Quarterly Federal Tax Return, for the first quarter of the calendar year and depositing any undeposited income, Social Security, and Medicare taxes. You may pay these taxes with Form 941 if your total tax liability for the quarter is less than $2,500. If you timely deposited all taxes when due, you may file by May 10.
Removal of OSHA Form 300A
Employers are required to post OSHA Form 300A, Summary of Work-Related Injuries and Illnesses, from February 1 – April 30. The summary must be displayed each year between February 1 and April 30 in a common area where notices to employees are usually posted.
Prescription Drug Data Collection Reporting
The Consolidated Appropriations Act, 2021 (CAA), Title II, Division BB contains a reporting requirement for group health plans and health insurers to submit data regarding drug costs to the Department of Treasury, Department of Labor (DOL) and Health and Human Services (HHS). Reporting is due annually on June 1, or the first business day after, if June 1 falls on a weekend day or holiday.
Form 5500 Filing Deadline (calendar year plans)
The deadline for filing Form 5500 for calendar year plans (without extension) is July 31, 2024. Plan sponsors may file Form 5558, Application for Extension of Time to File Certain Employee Plan Returns, to obtain an extension until October 15, 2024.
Form 941 Filing Deadline (second quarter)
Deadline for filing Form 941, Employer’s Quarterly Federal Tax Return, for the second quarter of the calendar year and depositing any undeposited income, Social Security, and Medicare Taxes. You may pay these taxes with Form 941 if your total tax liability for the quarter is less than $2,500. If you timely deposited all taxes when due, you may file by August 10.
PCORI Fee Deadline
The Affordable Care Act imposes a fee on issuers of specified health insurance policies and plan sponsors of applicable self-insured health plans to help fund the Patient-Centered Outcomes Research Institute (PCORI). The fee, which is required to be reported only once per year on the second quarter Form 720, Quarterly Federal Excise Tax Return, and paid by its due date, July 31st, is based on the average number of lives covered under the policy or plan.
VETS-4212 Filing Open (federal contractors)
The VETS-4212 Report must be completed by all nonexempt federal contractors and subcontractors with a contract or subcontract of $150,000 or more with any U.S. department or agency for the procurement of personal property or nonpersonal services. Services include but are not limited to utility, construction, transportation, research, insurance, and fund depository, irrespective of whether the government is the purchaser or seller. Entering into a covered federal contract or subcontract during a given calendar year establishes the requirement to file a VETS-4212 Report during the following calendar year.
The 2024 filing season for the VETS-4212 starts on August 1, 2025 and ends on September 30, 2025.
Summary Annual Report (SAR) Deadline (For Calendar Year Plans)
ERISA plan administrators are required to provide covered participants and certain beneficiaries with an annual statement summarizing the latest annual report Form 5500 for the plan. The SAR is due within nine months of the close of the plan year; two months after the extended due date for filing the Form 5500. DOL regulations require that certain categories of information be covered in the SAR. A sample SAR is included in the DOL regulations (29 CFR 2520.104b-10), and the DOL also provides a SAR template. (Due September 30, 2025, for calendar year plans; December 15, 2025, if an extension is filed.)
VETS-4212 Filing Deadline (federal contractors)
The deadline for federal contractors to file the VETS-4212 Report is September 30. The VETS-4212 Report must be completed by all nonexempt federal contractors and subcontractors with a contract or subcontract of $150,000 or more with any U.S. department or agency for the procurement of personal property or nonpersonal services. Services include, but are not limited to: utility, construction, transportation, research, insurance, and fund depository, irrespective of whether the government is the purchaser or seller. Entering into a covered federal contract or subcontract during a given calendar year establishes the requirement to file a VETS-4212 Report during the following calendar year.
QSEHRA Notice Deadline (Calendar Year Plans Only)
Small employers that offer a Qualified Small Employer Health Reimbursement Arrangement (QSEHRA) are required to provide written notice to eligible participants at least 90 days before the beginning of each plan year. Sample language is provided under Q&A #38 of IRS Notice 2017-67.
Medicare Part D Creditable/Noncreditable Coverage Notice
The Centers for Medicare and Medicaid Services (CMS) requires plan sponsors that provide prescription drug coverage to furnish Part-D-eligible individuals with a notice disclosing the creditable or non-creditable status of their coverage before October 15, 2025.
Form 941 Filing Deadline (third quarter)
Deadline for filing Form 941. Employer’s Quarterly Federal Tax Return, for the thrid quarter of the calendar year and depositing and undeposited income, Social Security, and Medicare taxes. You may pay these taxes with Form 941 if your total tax liability for the quarter is less than $2,500. If you timely deposited all taxes when due, you may file by November 10.
Gag Clause Prohibition Compliance Attestation
The Consolidated Appropriations Act, 2021, Title II, Division BB contains a reporting requirement for group health plans and health insurers to submit a Gag Clause Prohibition Compliance Attestation (GCPCA) annually through the Center for Medicare & Medicaid Services’ Health Insurance Oversight Systems to confirm compliance with the prohibition. Reporting is due by December 31, 2025.