Insights > Benefits > Small group special enrollment period (SEP): A guide for employers

Updated: July 31, 2026 • 7 min read

Small group special enrollment period (SEP): A guide for employers

Published By:

Jon Davis

The small-group special enrollment period (SEP) runs from November 15 to December 15 each year. During this window, health insurance carriers waive standard minimum participation and contribution rules — making it much easier for small businesses to launch a group health plan.

Key takeaways

  • Special Enrollment Periods (SEPs) allow eligible employees and dependents to join a group health plan outside annual open enrollment following specific life events.
  • The annual Special Open Enrollment Window (SOEW) — from November 15 to December 15 — lets small businesses enroll in group coverage without meeting standard participation or contribution minimums.
  • While small businesses can set up health plans year-round, the November 15 to December 15 window offers an annual chance to lock in January 1 coverage regardless of employee participation.

While companies can set up a small-group health plan at any time of year, many small businesses take advantage of the special enrollment period because the rules are waived.This guide explains how the special enrollment period works, potential savings, and why many small businesses set up health insurance with their broker during this timeframe.

What is a small group special enrollment period (SEP)?

First things first. The small group special enrollment period — also known as the Special Open Enrollment Window (SOEW) or Annual SEP — is a specific annual window running from November 15 to December 15 created under the Affordable Care Act (ACA).

 

It gives business owners with one to 49 full-time employees the opportunity to set up a group health plan without meeting standard carrier rules, like requiring 50 percent to 70 percent employee participation or a minimum employer premium contribution.

Take this step before the SEP

“When taking advantage of the special enrollment period, early planning makes all the difference. While the window opens in November, reach out to your broker right after Labor Day, so you have plenty of time to evaluate options and gather paperwork.”


— Andew Rothenberg, Vice President of Insurance, OnPay

Why the November 15 to December 15 window matters

During most of the year, insurance carriers require small businesses to meet two main criteria before issuing a group health policy:

  • Minimum participation: A specific percentage of your staff (often 50 percent to 70 percent) must enroll in the plan.
  • Minimum contribution: Your business must pay a required portion of employee monthly premiums.

 

If lower-wage workers waive coverage or your budget limits employer contributions, meeting those requirements can feel like spinning your wheels.

 

The annual Special Open Enrollment Window (SOEW) removes those roadblocks. Under the Affordable Care Act (ACA), fully insured small group carriers must accept eligible small businesses that apply between November 15 and December 15 — even if only one employee chooses to enroll and regardless of how much the business contributes toward premiums. Coverage takes effect on January 1.

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Can a new business start a small group plan at any time of year?

Yes. If you recently started a company or hired your first W-2 employee, you do not have to wait until November 15 to establish group health insurance. You can set up a small-group health plan at any point during the year.

 

However, if you set up a plan outside the November 15 to December 15 window, standard carrier minimum participation and contribution rules will apply. If you cannot meet those requirements mid-year, waiting for the annual special enrollment window is often the most strategic move.

Help should be standard

“Navigating enrollment windows shouldn’t fall entirely on your shoulders. A great benefits broker will reach out early to explain the “why” behind how the special enrollment window works for your business. If those conversations aren’t happening, your broker may not be providing the proactive support you deserve.”


— Andew Rothenberg, Vice President of Insurance, OnPay

How Section 125 plans unlock pre-tax savings for your team

Even if your business chooses to contribute zero dollars toward employee premiums during the special enrollment window, offering group health coverage still delivers major value. When you establish a group health plan alongside a Section 125 Premium Only Plan (POP), employees can pay their health insurance premiums using pre-tax payroll deductions. This lowers their taxable income and reduces their payroll taxes.

Simplicity and value

“OnPay is an excellent payroll processing company that makes processing payroll simple, handles all the reporting for me, and is a great value. And because it handles reporting requirements and filings for me, it frees up time to grow my business.”


— Rossana Bafaro, Il Paesano Corporation

Why offer benefits?

Adding a benefits program to your company is one of those steps that sets you apart from the competition when attracting top job seekers. But in most cases, it’s table stakes. Chances are you will need to offer benefits as part of your overall compensation package just to keep pace with other companies in your industry.

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Put the special enrollment period on your radar

Offering employee benefits can make you a more attractive employer. But since not every small business can meet carrier participation thresholds year-round, many employers mark the special enrollment period on their calendars.

 

This annual window provides an opportunity to waive standard rules, allowing you to strategize a benefits program with your broker. With November 15 around the corner, it’s a great time to schedule a chat with your benefits consultant to take advantage of this window.

 

Disclaimer: This guide provides general information for employers and brokers, not legal or tax advice. Always review your plan document, carrier guidelines, state laws, and federal regulations before approving or denying requests.

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Jon Davis is the Sr. Content Marketing Manager at OnPay. He has over 15 years of experience writing for small and growing businesses. Jon lives and works in Atlanta.

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