The HCA Brief – October 2026

By Sorren Human Capital Advisory | October 2026 Edition · 3-Minute Read

Julie’s Corner

A Note From Julie

October kicks off the final quarter of the year, so now is the time to start buttoning up year-end tasks and preparing to finish strong. With big holidays coming up in November and December, now’s a great time to focus on some of the key year-end wrap-up tasks that need to get done so you can set yourself up for success in 2027.

This month’s HCA Brief walks you through six priorities your HR team should be moving on in October: filing Q3 payroll forms, launching open enrollment, preparing for annual performance reviews and compensation decisions, celebrating Cybersecurity Awareness Month, getting ready for Election Day, and preparing for October compliance updates.

— Julie Cummings, National HCA Managing Partner

HR Headlines

What’s Moving in Employment Law

October signals the start of Q4 and the home stretch of the year. Here are the six most critical priorities your HR team needs to act on now.

File Q3 Payroll Forms

Your Q3 Form 941 is normally due October 31, but you have until November 2 this year since the 31st falls on a Saturday. If you made timely deposits in full payment of your Q3 taxes, you have until November 10 to file. Use the current March 2026 version of the form and reconcile wages, withholding, benefits and tax deposits before filing.

Launch Open Enrollment

For many employers, open enrollment officially kicks off in October. Distribute Medicare Part D creditable coverage notices to all Medicare-eligible participants before October 15 — a hard federal deadline. Map your communications calendar, stress-test your enrollment system, and educate managers on talking points and key deadlines.

Prepare for Annual Performance Reviews and Compensation Decisions

Organizations that prepare early — and prepare their managers early — are better positioned to deliver consistent, meaningful reviews. Audit performance management systems, train managers on fair and constructive reviews, and run a pay equity audit before merit and bonus decisions are finalized.

Celebrate Cybersecurity Awareness Month

October is Cybersecurity Awareness Month. Partner with IT and Security teams to launch awareness campaigns, provide refresher training on phishing, social engineering, AI-generated scams and deepfake threats, and conduct phishing simulations or tabletop exercises to help employees practice identifying threats.

Get Ready for Election Day

Election Day falls on November 3, 2026. While there is no federal law mandating voting leave, most states require employers to give employees time off to vote. Confirm your obligations in every state where you operate, communicate voting leave procedures to managers and employees before end of October, and plan coverage for November 3.

Prepare for October Compliance Updates

Notable updates take effect October 1: Connecticut pay transparency in job postings, Connecticut algorithmic discrimination liability, Maryland captive audience meeting protections, New Jersey independent contractor classification rules, and Washington I-9 audit notice requirements. Also: OFCCP rescinds affirmative action regulations effective October 26.

Monthly Checklist

October Employer Compliance Checklist

Use this checklist to confirm your organization is current on critical October obligations.

Reconcile Q3 wages, withholdings and deposits before filing Form 941
Use the current March 2026 version of Form 941 and complete any refund or aggregate-filer fields
If using a third-party payroll provider, confirm they are using the correct version of the form
Ensure any balance-due payment will be made electronically
File by November 2 (or November 10 if you qualify) and retain supporting payroll records
Distribute Medicare Part D creditable coverage notices to Medicare-eligible participants by October 15
Confirm full open enrollment notice package is ready (SBC, CHIP notice, WHCRA notice, HIPAA special enrollment rights)
Map out open enrollment communications calendar with multiple channels
Stress-test enrollment system before the window opens
Educate managers on open enrollment talking points, key deadlines and escalation procedures
Confirm annual performance review deadlines, workflows and responsibilities
Train managers on fair, objective and constructive performance reviews
Run a pay equity audit before merit and bonus decisions are finalized
Partner with IT and Security to launch Cybersecurity Awareness Month campaign
Provide refresher training on phishing, social engineering, AI-generated scams and deepfake threats
Confirm voting leave obligations in every state where you operate
Communicate voting leave procedures to managers and employees before end of October
Review Connecticut job posting templates for pay transparency compliance (effective October 1)
Inventory AI and automated decision-making tools used in HR functions (Connecticut AEDT law, effective October 1)
Review policies governing mandatory employee meetings for Maryland captive audience law (effective October 1)
Inventory all independent contractor relationships for New Jersey ABC Test compliance (effective October 1)
Update Form I-9 audit response procedures for Washington employee notice requirements (effective October 1)
Conduct legal review before modifying affirmative action programs (OFCCP rescinds EO 11246 regulations, effective October 26)

Practical HR Tip

This Month’s HR Insight

💡 Use October’s Q4 Kickoff as a Strategic Reset

October is one of the most action-packed months on the HR calendar — open enrollment, Q3 payroll filings, performance review prep, a wave of compliance updates, and Election Day all converge at once.

The organizations that navigate Q4 successfully are the ones that treat October as a planning month, not just an execution month. That means assigning clear owners to each priority, building in buffer time before hard deadlines, and making sure managers are equipped — not just informed.

This month, try a quick ‘Q4 readiness check’ with your HR leadership team: What’s on track? What needs a deadline? What needs an owner? A 30- minute conversation now can prevent a December scramble.

— HCA team

Workplace Trend

Data Worth Noting

Oct 15

Medicare Part D Deadline

The Medicare Part D creditable coverage notice deadline is one of the most commonly missed open enrollment compliance obligations. Notices must be distributed to all Medicare-eligible participants before October 15 each year. — Federal CMS Requirement

2 in 3

employees say

Two in three employees report feeling confused or overwhelmed during open enrollment, yet fewer than half say their employer provided enough guidance. Clear, multi-channel communications dramatically improve enrollment outcomes and reduce errors. — SHRM Benefits Survey

October’s compliance wave — six new state and federal updates — makes this one of the most regulation-dense months of the year. Early action is essential.

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Ask HCA

Your Question, Answered

❓ “We operate in Connecticut, New Jersey, and Washington. What do we need to do before October 1?”

Plan now, and you can be ahead of the changes!

In Connecticut, two laws take effect October 1. First, employers must include pay range information and a general description of benefits in all job postings for positions based in Connecticut or reporting to a Connecticut supervisor or location. Review your job posting templates, validate salary ranges, and train recruiters and hiring managers on the new requirements. Second, Connecticut’s Fair Employment Practices Act now explicitly states that using automated employment decision technology (AEDT) is not a defense to a discrimination complaint. Inventory your AI and automated HR tools, review vendor contracts, and establish human review processes for AI-generated recommendations.

In New Jersey, new regulations interpreting the ABC Test for independent contractor classification take effect October 1. Review all contractor relationships and agreements for compliance with the three-prong test covering control, usual course of business, and independent trade or business establishment.

In Washington, the new Immigrant Worker Protection Act requires employers to provide written notice to employees of upcoming Form I-9 inspections and notify affected workers of inspection results. Update your audit response procedures and prepare employee communication templates before October 1.

Sorren HCA can help you draft compliant policies, train your teams, and audit open compliance matters.

Contact us at HCA@sorren.com