The Department of Labor’s Employee Benefits Security Administration proposed a rule on July 22, 2026, that would let ERISA-covered group health plans deliver required disclosures electronically by default, instead of by mail. The safe harbor would apply to roughly 2.8 million group health plans and cover documents such as summary plan descriptions, claims denials, and COBRA continuation notices. EBSA estimates the change could save $3.9 billion over ten years by cutting the roughly 11 billion sheets of paper group health plans currently print and mail every year.

For HR and benefits teams, this is bigger than a paperwork tweak. Current rules limit electronic delivery mostly to employees who are “wired at work” or who affirmatively opt in, which forces many employers to run parallel paper and digital disclosure processes for the same workforce. A broader digital-by-default safe harbor would let benefits administrators consolidate onto a single communication channel, but only for the plans and vendors that already have the infrastructure, verified employee contact data, and consent workflows to do it compliantly. Acting Secretary Keith Sonderling framed the goal as replacing “outdated paperwork with clear, accessible digital tools,” while Assistant Secretary Daniel Aronowitz said the change would “make it easier for people to access and manage their health plan documents online.”

The original insight for benefits leaders is timing, not enthusiasm. This is a proposed rule, not a final one, and the comment period will shape how much consent documentation employers still need to keep. Teams that wait for the final rule to start modernizing plan-communication systems will be building under deadline pressure. Teams that treat this proposal as a signal to audit their current disclosure workflows now, alongside the cost pressure already building from rising ACA marketplace premiums heading into 2027, will be ready to move the moment the safe harbor is finalized.

Source: U.S. Department of Labor, Employee Benefits Security Administration