• Brown & Brown urged employers to update PBM contracts for enhanced compensation disclosures covering plan years beginning on or after July 1, 2027.
• The Labor Department’s final rule covers self-funded ERISA plans with at least 100 participants or sponsors averaging at least 100 employees.
• PBMs must provide initial compensation disclosures at least 90 days before contracts begin, renew or extend.
• Ongoing disclosures are due within 30 days of each six-month period; plans can request quarterly reporting.
• Plan fiduciaries must monitor compliance, seek corrections for deficient disclosures and report uncorrected failures to the Labor Department.

Disclaimer: This news brief was created by Public Technologies (PUBT) using generative artificial intelligence. While PUBT strives to provide accurate and timely information, this AI-generated content is for informational purposes only and should not be interpreted as financial, investment, or legal advice. Brown & Brown Inc. published the original content used to generate this news brief on November 04, 2026, and is solely responsible for the information contained therein.