Understand ICHRA Enrollment Deadlines and Effective Dates

Learn how ICHRA and insurance enrollment deadlines differ and what determines when an employee's coverage can take effect.

Sep 7, 2026

Employees enroll during the annual Individual Market Open Enrollment Period or through a special enrollment period. Open enrollment dates vary by Marketplace and plan year, so confirm the applicable dates with the federal or state-based Marketplace.

A new ICHRA offer may create a special enrollment period if the employee meets the applicable requirements. The available enrollment window and effective-date rules depend on the employee's circumstances, enrollment date, state, and enrollment path.

There are two different deadlines to communicate:

  • ICHRA deadline: Gives the employer time to prepare eligibility, allowance, payroll, and administrative records.

  • Insurance enrollment deadline: Determines whether the employee can submit an insurance application for the requested effective date.

Missing an employer deadline does not extend an insurance enrollment window. Likewise, submitting information to Lirvion does not preserve an enrollment opportunity if the insurance application is not completed.

The requested coverage effective date must also align with the employee's ICHRA eligibility date, prior coverage, available enrollment period, carrier rules, plan terms, and any required initial premium.

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