Small Business Open Enrollment: The November 15 to December 15 Window

By Michael Sprague, Licensed Health Insurance Agent · Reviewed by Heather Sprague, Licensed Health Insurance Agent

Small business open enrollment is a yearly window, from November 15 to December 15, when small employers can start a group health plan without meeting the usual participation or contribution rules. Coverage starts January 1.

It is often called the small group special enrollment period or special open enrollment window. If you have had trouble getting enough employees to sign up, this is the month that removes that barrier. Questions? Call 888-730-6031 to talk with a licensed agent.

What Is the Small Group Special Enrollment Window?

Federal rules let small group carriers limit coverage for employers who cannot meet a plan's participation or contribution rules. The catch is that carriers must accept those employers during an annual window that runs from November 15 through December 15.

In practice, this means almost any eligible small business can buy a fully insured group plan during this month, no matter how many workers enroll or how little the employer pays toward premiums. The same waiver applies to SHOP Marketplace coverage.

What Gets Waived and What Does Not

Only two rules are waived. Everything else is the same as the rest of the year.

Rule	Normal months	Nov 15 to Dec 15
Minimum participation	Often 50% to 75% of eligible employees	Waived
Minimum employer contribution	Often 50% of employee-only premium	Waived
At least one eligible non-owner employee	Required	Still required
Proof of employment (payroll or wage report)	Required	Still required
Business in good standing, tax ID	Required	Still required
Effective date	First of any month	January 1

Who Should Use This Window?

• Businesses where only one or two employees want coverage because others have a spouse's plan, Medicaid or Medicare.
• Owners who cannot afford to pay half the premium yet but want to offer a plan.
• Businesses that were declined earlier in the year for low participation.
• Employers moving from an HRA or individual reimbursements to a group plan.
• Small teams that want a January 1 start to match the calendar year.

Key Dates and Deadlines

The legal window is November 15 to December 15. However, carriers and general agencies often set earlier internal cutoffs for paperwork, payroll records and the first premium payment. Missing a cutoff can push you past the window.

A simple timeline looks like this:

• Early November: count employees, set a budget and survey your team.
• November 15 to 30: compare plans and quotes, then pick a plan.
• Early December: submit the application, payroll records and first payment.
• December 15: the window closes.
• January 1: coverage begins.

What You Need to Apply

Have these ready before you start:

• Your federal employer ID number (EIN) and business address.
• A recent payroll report or state quarterly wage filing that lists employees.
• A census of employees with dates of birth, ZIP codes and who wants coverage.
• A list of employees declining coverage and why, if the carrier asks.
• The first month's premium payment.

Group Plan vs HRA: Which Is Right for You?

Usually no. The window waives participation and contribution rules, but a group plan still needs at least one eligible employee who is not an owner or the owner's spouse. If you are the only person in your business, look at individual coverage instead. Our guide to self-employed health insurance explains your options.

Group Plan vs HRA: Which Is Right Right Now?

If you want a single plan for everyone and can enroll during the window, a group plan may be simplest. If you want a fixed budget or have employees in different areas, an ICHRA or QSEHRA may fit better. HRAs do not depend on this window, though you must give employees notice before the plan year, usually 90 days for a QSEHRA and an ICHRA.

Employees covered by an HRA buy their own plans. The ACA individual open enrollment period for January 1 coverage generally ends December 15 in most states, so timing still matters.

After the Window Closes

If you miss December 15, you can still start a group plan in any month if you meet the carrier's participation and contribution rules. You can also start an ICHRA at any time with proper notice. Your employees may still get individual coverage during their own open enrollment or a special enrollment period.

What Will a Plan Started in This Window Cost?

The window changes who can buy, not the price. Small group premiums are set by age, location, plan level and family size. KFF found average 2025 premiums of $9,211 a year for single coverage at firms with 10 to 199 workers. That is roughly $768 a month before your contribution.

Because no minimum contribution applies, you can choose to pay a smaller share at first and raise it later at renewal. Just know that a low contribution may lead fewer employees to enroll.

Common Mistakes to Avoid

• Waiting until the second week of December and missing a carrier cutoff.
• Assuming the waiver covers an owner-only business.
• Forgetting to list employees who decline coverage.
• Choosing a plan without checking that key doctors are in network.
• Leaving out a pre-tax premium-only plan, which costs employees more.

Tips to Get the Most from Small Business Open Enrollment

• Get quotes for more than one plan level so employees can see the trade-off between premium and deductible.
• Ask about a Section 125 premium-only plan so employees pay their share pre-tax.
• Check whether you qualify for the small business health care tax credit.
• Consider adding dental and vision so your package feels complete.
• Keep signed waivers for employees who decline.

Small Business Open Enrollment: FAQ

When is small business open enrollment?

November 15 through December 15 each year, for coverage that starts January 1.

Do I need a minimum number of employees to enroll?

Not during the window. You still need at least one eligible employee who is not an owner or owner's spouse.

Do I have to pay 50% of premiums?

No. Minimum contribution rules are waived for applications made during the window.

Is this the same as ACA open enrollment?

No. ACA open enrollment is for individuals and families. This window is for small employers buying group coverage.

Can I apply on December 15?

Legally yes, but many carriers have earlier paperwork cutoffs. Apply as early as you can.

Next Steps for small business open enrollment

If you want group coverage starting January 1 and worry about participation or cost, use this window. Set your budget, gather payroll records and compare plans before December. For the full picture, see our guide to small business health insurance.

Want a licensed agent to help? Call 888-730-6031, Monday through Friday, 9 a.m. to 6 p.m. Eastern, or request a free quote.

Sources

1. 45 CFR 147.104: Guaranteed availability of coverage
2. HealthCare.gov: SHOP coverage for small businesses
3. KFF 2025 Employer Health Benefits Survey

Related Guides

• Small business health insurance
• ICHRA health insurance
• QSEHRA for small business
• Self-employed health insurance

Vivna Insurance is a licensed independent agency, not a government website. Our help is free; we are paid by the insurance companies we work with. Coverage options, deadlines and costs vary by plan and state.