Your SAR Is Due September 30. Most Employers Miss It.

What the SAR Actually Is

The Summary Annual Report isn't optional paperwork. It's a federally required summary of your Form 5500, and ERISA mandates you distribute it to every plan participant and beneficiary. According to Amicum Financial Group, the SAR is a concise summary of the Form 5500 filed with the Employee Benefits Security Administration.

Miss it, and you're looking at DOL enforcement exposure. Most CFOs know about the Form 5500. Fewer track the SAR deadline that follows it.

They're linked. That connection is what trips employers up every year.

The Deadline Math for Calendar-Year Plans

Your plan year ended December 31, 2025. Your Form 5500 was due July 31, 2026. That makes your SAR deadline September 30, 2026, exactly nine months after plan year end and two months after the Form 5500 due date.

As PeopleKeep explains, the SAR deadline is always calculated as two months after the applicable Form 5500 due date. Whether that's the original July 31 deadline or the extended October 15 deadline, the formula is fixed. There's no separate SAR extension you can file on its own.

Did you file a Form 5500 extension by July 31? Then your Form 5500 is due October 15, and per Benefits Link / EBIA, your SAR deadline shifts to December 15. That's the only compliant path to a later SAR deadline.

What the SAR Must Contain

DOL regulations specify required content. The DOL ERISA SAR regulations analyzed by EBIA include model language you can use directly. For most health, dental, or vision plans, the required language follows a standard format.

Here's a working template for a calendar-year health plan:

• Plan name and employer identification number (EIN)
• Statement of assets and liabilities, pulled from the Form 5500 Schedule H or I
• Total plan expenses for the plan year
• Insurance information, including carrier name, contract number, and premiums paid
• Your right to additional information: a statement that participants can request a copy of the full Form 5500 from the plan administrator, free of charge, within 90 days of the request
• PBGC notice, if applicable to pension plans

Small ERISA pension plans qualifying under audit waiver provisions have specific model language available from the DOL. Per Benefits Link / EBIA, those plans should use that model audit waiver language in their SAR. Don't substitute general template language.

How to Distribute It

You have three compliant distribution methods. Hand delivery to participants at their worksite. First-class mail to the last known address.

Electronic delivery works too, but only if participants have regular work-related computer access or have affirmatively consented under the DOL's electronic disclosure rules.

Keep your distribution records. Date of delivery, method used, list of recipients. If the DOL comes asking, you need proof the SAR went out before September 30, not just that you drafted it.

The Decision You Already Made Is the One That Matters

Here's the problem most CFOs don't see until it's too late. Your only path to a December 15 SAR deadline was filing a Form 5500 extension by July 31. That decision had to be made months before the SAR was due.

If you didn't file that extension, September 30 is your hard deadline. No exceptions. Missing it exposes your plan to DOL enforcement and potential penalties under ERISA.

There's no grace period built into the regulation. There's no SAR-only extension you can file. The September 30 date is a hard operational milestone tied directly to whatever Form 5500 strategy you chose earlier this year.

If you're reading this in August or September and you haven't distributed yet, get it out this week.