Brown & Brown flags proposed DOL safe harbor for electronic delivery of ERISA group health plan disclosures

• Brown & Brown summarized a July 22, 2026 Labor Department proposal to expand ERISA electronic disclosure safe harbor rules for employer group health plans.
• The proposal would let plan sponsors post required disclosures on a website, then send a Notice of Internet Availability to participants.
• It would require an initial electronic-delivery notice, free paper copies on request, opt-out rights, and steps to maintain access post-termination.
• The approach would not apply to ERISA welfare benefit plans such as life or disability coverage.
• Brown & Brown flagged potential liability protection if finalized, while advising plans not to rely on the safe harbor until rules are final.

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