When Is the ICHRA Notice Due?
June 24, 2026 · 3 min read
If you''re setting up an ICHRA, one deadline matters more than the rest: the employee notice. Get the timing right and the rollout is smooth; miss it and you can create compliance and enrollment problems.
The standard deadline
Give eligible employees the ICHRA notice at least 90 days before the start of the plan year. For employees who become eligible mid-year (like new hires), provide it no later than the day their coverage can begin.
What the notice has to say
The notice isn''t just a formality. It tells employees the amount of their allowance, how the ICHRA works, and — importantly — how it interacts with ACA premium tax credits, so they can decide whether to take the ICHRA or a subsidy.
Why 90 days
Employees need time to shop for and enroll in individual coverage before the plan year starts. The runway is built into the rule on purpose — rushing it leaves employees scrambling to find a plan.
If you''re cutting it close
Talk to a broker — there are paths for newer or smaller employers, but the safe move is to plan your start date backward from the 90-day notice. A broker or administrator generates and tracks the notice for you so the deadline never sneaks up.
What the 90-day rule actually requires
An ICHRA must give eligible employees written notice at least 90 days before the start of each plan year. The notice explains the ICHRA terms and, importantly, how it interacts with premium tax credits, so employees can make an informed enrollment decision. Building the notice into your annual calendar keeps you compliant.
New hires and mid-year starts
The 90-day rule bends for people who become eligible partway through the year. For a new hire or an employee who becomes eligible mid-year, the notice is generally due no later than the first day their ICHRA coverage takes effect, rather than 90 days in advance.
If you're running late
Missing the notice deadline is a compliance risk, not something to shrug off — it can affect employees' subsidy decisions and your standing. If you are behind, send the notice as soon as possible and talk to a broker or advisor about the right way to correct course.
Frequently asked questions
Generally at least 90 days before the start of the plan year. New hires who become eligible mid-year get it no later than the day their coverage can begin.
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