As we move into the second quarter of 2026 and spring approaches, this is an ideal time for employers to conduct a comprehensive compliance review. Spring cleaning should extend beyond clearing files or refreshing templates. It is an opportunity to confirm that your policies, reporting obligations, and documentation practices align with current federal, state, and local requirements. With several legislative updates already in effect this year, a proactive review now can reduce risk and prevent avoidable exposure later.
Who Should Be Paying Attention?
While certain obligations vary based on employer size, industry, or plan structure, nearly every organization benefits from a structured compliance review this time of year. Spring is an opportunity to take inventory of core employment practices, reporting requirements, and documentation controls to ensure they remain current, accurate, and defensible. Addressing these areas proactively reduces regulatory exposure and positions the organization for a stable and compliant year ahead.
What Should Employers Be Reviewing?
- AI Governance Strategy. Artificial intelligence has moved from concept to daily practice in many workplaces. Employers using AI to support recruiting, screening, performance management, or other employment decisions should confirm that clear guardrails are in place. Policies should define acceptable use, assign oversight responsibility, require meaningful human review, and address data privacy and bias mitigation in writing rather than through informal practice.
- Remote Work and Hybrid Policies. Remote and hybrid work policies and agreements also warrant review. Expectations regarding work hours, availability, communication protocols, and data security should be clearly articulated and adjusted based on operational needs. Employers should confirm who is responsible for company issued equipment and what safeguards employees must follow when working off site. Ambiguity in these areas can create wage and hour risk, data security exposure, and performance management challenges.
- EEO-1 Reporting Preparation. For employers subject to EEO-1 reporting (i.e., 100 or more employees), now is the time to review workforce data before the filing window opens. Employees should be mapped to the correct EEO-1 job category based on actual job duties, not internal titles. Human resource teams should run reports to identify missing race, ethnicity, or sex data and confirm that the fourth quarter workforce snapshot period from October 1 through December 31 has been properly captured. Addressing data integrity concerns now reduces the likelihood of filing issues later.
- ACA Reporting. Affordable Care Act reporting requirements have shifted in meaningful ways. While the annual furnishing deadline for Forms 1095-B and 1095-C has recently passed for calendar year filers, employers are no longer required to automatically distribute these forms if they provide a compliant advance notice and furnish the form upon request. Employers should confirm that proper notice was issued, request procedures are documented, and internal teams understand response timelines. In addition, organizations should update policies to reflect the expanded 90-day response period for proposed Employer Shared Responsibility Payment assessments and the applicable six-year statute of limitations. Reviewing these processes now supports defensible compliance for the current reporting cycle and beyond.
- Medicare Part D Compliance. Employers offering calendar year prescription drug coverage must satisfy two distinct Medicare Part D obligations. For calendar year plans, the annual online disclosure to the Centers for Medicare and Medicaid Services is due within 60 days of the start of the plan year. Employers should confirm that this filing was completed timely and that submission confirmation is retained. If the deadline is missed, the disclosure should be submitted as soon as possible and the corrective action documented. Employers must also distribute a written Creditable Coverage Notice to Medicare eligible employees and dependents before October 15 each year and at other required triggering events. Because these obligations carry different deadlines, both the CMS filing and participant notice process should be tracked and documented.
- OSHA Forms and Reporting. Workplace safety obligations should not be overlooked. OSHA Form 300A must remain posted in a conspicuous location through April 30, 2026. Employers subject to electronic reporting requirements were required to submit injury and illness data through OSHA’s Injury Tracking Application (ITA) by March 2, 2026. Employers that missed the deadline should submit the required data as soon as possible. Although late submissions do not eliminate potential liability, prompt corrective action may help demonstrate good faith compliance efforts.
- Records Review. Finally, spring is an appropriate time to reconcile documentation practices. Federal and state laws prescribe specific retention periods for employment records, and discarding documents too early or retaining sensitive information too long can create unnecessary compliance risk. Employers should review record retention schedules, securely purge outdated files, and audit Forms I-9 to identify upcoming work authorization expirations and ensure timely reverification. Strong retention and destruction practices are not simply administrative tasks; they are essential to defensible compliance and litigation readiness.
Next Steps for Employers
Organizations that approach compliance through structured quarterly reviews are better positioned to manage regulatory change and operational risk. Establishing clear ownership, documenting completion of required filings, and maintaining a centralized compliance calendar can help prevent gaps. When updates are made, revised policies should be redistributed and acknowledgments retained to preserve defensibility.
This overview is intended for general informational purposes. Because requirements vary based on employer size, industry, and jurisdiction, organizations should consult legal counsel or a qualified human resource compliance professional to assess their specific obligations.
How HR Works Can Help
Staying ahead of rapidly evolving workplace laws is critical to mitigating risk. Current HR Works clients can contact the Virtual Helpline or their designated HR Consultant to ensure your policies and practices are compliant with the new 2026 requirements.
