The DOL’s PBM disclosure rule, in plain English

What the Department of Labor’s final rule asks of pharmacy benefit managers, when it applies, and what it leaves to plan sponsors.

The rule at a glance

Finalized: October 29, 2026, by the Department of Labor’s Employee Benefits Security Administration. It implements the PBM provisions of the Consolidated Appropriations Act, 2026.
Applies to: Plan years beginning on or after July 1, 2027. It is not in force for today’s renewals.
Who is covered: Large self-insured ERISA plans: generally 100 or more participants, or employers with 100 or more employees.
Before a contract or renewal: The PBM discloses in writing what it expects to earn. At least 90 days ahead is treated as reasonable.
Every six months: The PBM reports what it actually earned, or quarterly if the plan asks.
In what form: Stated in dollars, with a machine-readable file available on request.
Audit right: At least once a year, with an auditor the plan chooses.
Projected impact: The DOL projects $22 billion in lower drug costs for employers and workers over a decade. That is a projection, not money returned to plans.
Status: The PBM trade group says the rule goes beyond the DOL’s authority. A legal challenge is expected.

Disclosures are reported by the PBM itself. The plan gets an audit right, not an independent price test.

Acting on what the disclosures show stays with the plan fiduciary.

It is an ERISA rule. Governmental plans, such as many public employers, generally fall outside it.

Your PBM will start reporting what it earns. An Expose FI Snapshot gives you a baseline from your own claims, so you can check what it tells you.

This page is general information, not legal advice. Ask your benefits counsel how the rule applies to your plan.

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