Short answer: SBCs may be delivered either electronically or in paper form, but electronic delivery is allowed only if specific federal requirements are met.
Employers and insurers may distribute a Summary of Benefits and Coverage (SBC) using either paper or electronic delivery methods, as long as the applicable federal rules are followed.
Paper delivery satisfies SBC requirements without additional conditions. SBCs may be mailed to employees’ homes or handed out directly, and no special consent is required when paper delivery is used.
Electronic delivery is permitted, but only in certain situations. For employees who regularly use a computer as part of their job duties, such as those with routine work-related email access, the SBC may be delivered electronically through workplace systems. For all other employees, electronic delivery is allowed only if the individual has affirmatively consented to receive documents electronically in accordance with federal rules.
If the requirements for electronic delivery are not met, a paper SBC must be provided unless and until the employee opts into electronic delivery. When electronic delivery is used, the SBC must be readily accessible, provided in a usable format, and accompanied by a notice explaining the significance of the document.
Federal electronic disclosure rules are enforced by the U.S. Department of Labor and apply to both employers and insurers responsible for SBC distribution.
Sources
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U.S. Department of Labor, Electronic Disclosure Safe Harbor
https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/faqs/electronic-disclosure -
Centers for Medicare & Medicaid Services, Summary of Benefits and Coverage (SBC)
https://www.cms.gov/cciio/resources/forms-reports-and-other-resources/summary-of-benefits-and-coverage -
29 CFR §2520.104b-1
Content history
Originally published: June 16, 2025
Last reviewed: January 25, 2026