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ARTICLE · 24 JULY 2026

DOL Proposes Electronic Disclosure Safe Harbor For Health Plan Documents

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The US Department of Labor has proposed a new electronic disclosure safe harbor specifically for ERISA-covered group health plans, potentially transforming how plan administrators deliver required disclosures to participants. This proposed framework would mirror the 2020 retirement plan e-disclosure safe harbor by enabling default electronic delivery through a notice-and-access model, moving away from the outdated 2002 consent-based standard. The DOL projects this change could raise electronic delivery rate

United StatesEmployment and HR
Hillary E. August
Hillary E. August
Grant G. Uhler
Grant G. Uhler
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A New E-Disclosure Framework for ERISA Group Health Plans

On July 23, the US Department of Labor published a proposed rule in the Federal Register that would create a new electronic disclosure safe harbor for ERISA-covered group health plan. If finalized, the proposal would give group health plan administrators an additional, optional pathway to deliver required ERISA disclosures electronically, alongside the existing 2002 e-disclosure safe harbor and the 2020 e-disclosure safe harbor available to retirement plan administrators.

The 2020 Retirement Plan and 2002 E-Disclosure Safe Harbors

In May 2020, the DOL issued final regulations permitting retirement plan administrators to deliver required ERISA disclosures electronically through an “opt-out” model under 29 C.F.R. § 2520.104b-31. Under the 2020 safe harbor, plan administrators may default to e-delivery for all participants so long as they satisfy a number of conditions, including providing an initial paper notice to

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