Filing a Late PCORI Return: What to Do Now

If you missed the July 31, 2026 PCORI deadline, the next step is the same as it was before the deadline: file the second-quarter Form 720 and pay what it shows. Being late doesn't change the form, the line, or the rate. It adds the chance of a penalty notice afterward, and that has its own procedure. Here is the order to work in.

Step 1: Confirm which plan year you missed

The return due July 31, 2026 covers plan and policy years that ended during 2025. If you are the sponsor of a self-insured plan or an HRA, these are your lines on the June 2026 form:

Insurers use lines 133(a) and 133(b) for policies. A plan year that ended in 2026 isn't late yet: it is due in 2027, on Monday, August 2, because July 31, 2027 is a Saturday.

If you realize that you also missed earlier years, each one has its own due date and rate. A plan year ended in 2024, for instance, belonged to the July 31, 2025 return, and one that ended before October 1, 2024 has a lower rate than the lines above. Talk to your advisor about those years, and start by listing every plan year that ended since the plan began.

If your coverage is fully insured and you have no HRA or other self-insured arrangement, you didn't miss anything, because the insurer is responsible for the fee.

Step 2: Check whether you already filed a second-quarter return

This step decides which form you need. IRS Q&A 8 says only one Form 720 should be filed for each quarter.

• You filed nothing for the second quarter of 2026. Continue below and file the return.
• You filed a second-quarter return for other excise taxes and left PCORI off. The instructions send adjustments for prior quarters to Form 720-X, and say not to enter them on Form 720. See our Form 720-X guide.
• You are about to file a third-quarter return. Don't add the fee there. The instructions say not to make an entry on the IRS No. 133 line on first, third, or fourth quarter filings.

Step 3: Count lives for that plan year and work out the fee

Pull enrollment records for the plan year you missed, and use the actual count or snapshot method. Dependents, COBRA participants, and retirees generally count. Sponsors with only an HRA or FSA may count one life per participant.

Snapshot needs counts on dates that match across the four quarters. They can be historical dates, as long as your records show who was covered on them. For a full walk-through of each method, see the covered lives guide.

Multiply average lives by the rate. Suppose a made-up employer, Riverbend Auto Group, has a self-insured plan with a year that ended December 31, 2025 and an average of 85 lives. The fee is 85 x $3.84 = $326.40, on line 133(d). If its plan year had ended June 30, 2025 instead, it would use $3.47 on line 133(c), for $294.95. The PCORI fee calculator will check your figure.

Both lines feed into the Tax column for IRS No. 133, then into the Part II total, then line 3 of Part III. Line 10 is the balance due.

Step 4: File the return and pay the balance

1. File. You can e-file through a participating provider, or mail the paper return to the Ogden address in the instructions. E-filing is available but not required.
2. Pay. The instructions list IRS Direct Pay, EFTPS, check or money order, or, if filing electronically, direct debit. If you use EFTPS, apply the payment to the second quarter. Don't file Form 720-V if you pay by Direct Pay, EFTPS, or direct debit.
3. If you can't pay it all, the instructions say you can apply online for an installment agreement if your combined tax, penalties, and interest are $25,000 or less ($50,000 for individuals) and you've filed all required returns. So file the return either way.

Step 5: Handle any penalty notice when it arrives

This is where people often go wrong, by attaching a letter to the return. The Form 720 instructions say: if you receive a notice about a penalty after you file, reply to the notice with an explanation, and the IRS will determine whether you meet reasonable-cause criteria. They also say not to include an explanation when you file your return.

So write your explanation now while the facts are fresh, and keep it for later. Good notes might cover what happened, when you found out, and when you fixed it. Whether a penalty applies, and whether it is removed, is up to the IRS. Pub. 510 lists filing returns late and paying taxes late among the acts that may result in penalties and interest. The Form 720 instructions don't set out a penalty rate schedule for this fee, so for the penalty detail and how the amounts work, read our article on PCORI late filing penalties.

Keep copies of the return and your counting records. The instructions say to keep records for at least 4 years from the latest of the date the tax became due, the date you paid it, or the date you filed a claim.

Starting the late return online today

If you have your plan-year count, you can begin now. Create a free EasyFile720 account with no credit card, enter your business details, and enter your average lives. The rates are built into the return and the math is calculated for you. You pay only when you file, at $39.95 per filing. Before you pay, check that the second quarter of 2026 is the return period shown. If you need a period that isn't offered, the paper return at the Ogden address is the alternative.

Validations catch common mistakes before you submit, you sign electronically, and you get an electronic acknowledgment from the IRS once the return is accepted, which gives you a record to have on hand if a notice arrives. The PCORI fee page sets out the rest of the return, and from there you can start your late PCORI filing.

FAQ

Sources: Instructions for Form 720 (Rev. June 2026); Form 720 (Rev. June 2026); IRS PCORI Questions and Answers (Q3, Q8, Q15, Q16); 26 CFR 46.4376-1; Pub. 510 (Rev. December 2025). General information, not tax advice. Confirm how the rules apply to you with a qualified advisor or the IRS.