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ARTICLE · 03 NOVEMBER 2026

DOL Issues Final Pharmacy Benefit Manager Transparency Rule: What Plan Sponsors Need To Know

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The US Department of Labor has issued a comprehensive final rule requiring pharmacy benefit managers to disclose detailed fee structures, manufacturer rebates, and compensation arrangements to ERISA group health plans. This regulation establishes extensive transparency requirements for PBMs serving large self-insured employer health plans, including pre-contracting disclosures, semiannual reporting obligations, and audit rights for plan fiduciaries to monitor PBM compensation and pricing practices.

United StatesEmployment and HR
Richard Nowak
Richard Nowak
Hillary E. August
Hillary E. August
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On October 29, 2026, the US Department of Labor (“DOL”) issued its long-awaited final transparency rule requiring pharmacy benefit managers (“PBMs”) to disclose fees, manufacturer rebates, and other forms of direct and indirect compensation to ERISA group health plans.1 The final rule, titled “Improving Transparency Into Pharmacy Benefit Manager Fee Disclosure” (the “PBM Regulation”), requires providers of PBM services, along with any affiliated brokers and consultants, to provide detailed compensation disclosures under ERISA Section 408(b)(2) to ERISA group health plan fiduciaries. Those disclosures include an initial disclosure before the plan enters into, renews, or extends a contract with a PBM, as well as at least semiannual disclosures showing the compensation actually received by the PBM and its affiliates. The PBM Regulation applies to plan years beginning on or after July 1, 2027.

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