Labor Department Expands Voluntary Compliance Program for Employee Benefit Reporting

Key Takeaways

• Voluntary Compliance Expanded: The U.S. Department of Labor has extended its Delinquent Filer Voluntary Compliance Program to include missed Form M-1 filings by Multiple Employer Welfare Arrangements.
• Relief From Penalties: MEWA administrators can now correct overdue filings voluntarily and significantly reduce or avoid civil penalties.
• Form M-1 Remains Central: The annual filing provides critical information about MEWA operations and supports employer decision-making and ERISA oversight.
• Compliance Over Enforcement: The expansion reflects a continued shift toward encouraging proactive compliance rather than relying solely on enforcement actions.

Deep Dive

The U.S. Department of Labor is giving benefit plan administrators more breathing room to fix past reporting missteps, expanding a long-running self-correction program to cover missed annual filings by Multiple Employer Welfare Arrangements.

The Department said its Employee Benefits Security Administration (EBSA) has extended the Delinquent Filer Voluntary Compliance (DFVC) Program to include MEWAs that failed to submit their required Form M-1 filings on time.

Form M-1 is a cornerstone disclosure for MEWAs and certain other entities that provide health and welfare benefits to employees of more than one employer. Filed annually, it lays out key details about a MEWA’s structure and operations, information regulators say helps employers decide whether to participate and supports oversight under the Employee Retirement Income Security Act. Missing the filing deadline can carry steep civil penalties.

Until now, however, MEWA administrators had few practical options to clean up those lapses voluntarily. The expansion of the DFVC Program changes that, creating a formal path for administrators to catch up on overdue filings, limit penalty exposure, and keep benefit arrangements on sound regulatory footing.

“The Delinquent Filer Voluntary Compliance Program has helped foster a culture of compliance and trust by giving plan officials the opportunity to proactively comply with the law,” said Keith Sonderling, the Deputy Secretary of Labor. “Expanding access to this program just makes sense. It supports responsible efforts to correct violations and helps us fulfill our mission to put both workers and employers first.”

The Department framed the update as a practical fix to a long-standing gap in its voluntary compliance toolkit. While the DFVC Program has long been available to other plan administrators seeking to resolve eligible reporting violations and reduce penalties, MEWA Form M-1 filings had been left outside that safety net.

For compliance and benefits teams overseeing multi-employer arrangements, the change offers a more constructive off-ramp from noncompliance. Rather than facing immediate enforcement risk, administrators now have a clearer opportunity to address missed filings, reinforce transparency, and ensure plan participants continue to receive the protections ERISA is meant to guarantee.

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