Regulatory Updates
DOL Updates Delinquent Filer Voluntary Compliance Program for MEWAs
Published December 30, 2025
The Department of Labor (DOL) Employee Benefits Security Administration (EBSA) has released a notice expanding the Delinquent Filer Voluntary Compliance Program to include administrators of multiple employer welfare arrangements (MEWAs) who fail to file a Form M-1 annually. The maximum penalty will be $750 for late filing of Form M-1.
The program changes include:
- Expanding the penalty relief to administrators of MEWAs that are not group health plans but provide benefits that consist of medical care (non-plan MEWAs) and entities claiming exception (ECEs) who are required to file the Form M-1.
- Extending to late Form M-1 filers the same $750 maximum penalty amount currently available to small plans filing a late Form 5500, and to filers of apprenticeship and training plans and top hat plans.
The enforcement policy change is effective December 31, 2025.