The Washington Report
November 19, 2025
While we do our best to provide timely updates, it is possible that the information shared in the newsletter may change after our publication deadline.
Note to Subscribers
The Washington Report will not be published on November 26, 2025. Look for your next Aon Washington Report on Wednesday, December 3, 2025. Happy Thanksgiving!
Aon Publications
Reminder: HIPAA Notices Should Be Updated by February 16, 2026
Although much of the 2024 HIPAA Privacy Rule was vacated in federal court, the requirement to revise the HIPAA notice of privacy practices (NPP) under the Part 2 Rule (relating to substance abuse information) remains in place. HIPAA covered entities (including group health plans) must update their NPP to reflect these changes by February 16, 2026.
The Aon bulletin is available here.
Now Available: Aon’s 2026 Compliance Calendar – Supporting Your Plan Administration
Aon is pleased to present its 2026 Compliance Calendar to assist plan sponsors and fiduciaries with identifying significant compensation and benefit due dates for their retirement and health and welfare plans. This Calendar covers major compliance dates for plans operating on a January 1 to December 31 calendar year, including deadlines for notice distributions, plan disclosures, federal regulatory filings, and other date-specific plan requirements. While some compliance dates may be subject to change due to the ongoing release of additional or clarifying legislative or regulatory guidance by the Internal Revenue Service (IRS), Department of Labor (DOL), or other federal agencies throughout the year, this Compliance Calendar should serve as a very useful tool to ensure timely compliance during 2026.
Some topics addressed in the 2026 Compliance Calendar include:
- Timing for participant communications and required notices (such as summaries of material modifications, pension benefit statements, and summaries of benefits and coverage);
- Updates to health plan reporting obligations;
- Due dates for plan contributions; and
- Filing deadlines for essential IRS and DOL forms (including Forms 5500, W-2, 1094 B, 1095-B, and 1099-R).
Please note that the Calendar is tailored for plans following a calendar year reporting cycle and may not apply to plans with fiscal year or other non-calendar reporting periods.
The 2026 Aon Compliance Calendar: Significant Retirement and Health & Welfare Plan Compliance Dates is available here.
IRS 2026 Official Indexed Figures for Retirement Plans and Other Employee Benefit Plans
The IRS issued Information Release 2025-111 on November 13, 2025, providing the 2026 official indexed figures for retirement plans and other employee benefit plans. The IRS issued technical guidance detailing these items in Notice 2025-67.
The Aon bulletin, which provides the official limits of most interest to large and medium-sized employers, as well as the official 2026 key employee pay thresholds for top-heavy plans, is available here.