Short answer: Generally no. SBCs must follow a strict federal template and cannot include agency branding or promotional material, although limited plan or employer contact information may appear in designated areas.
Summary of Benefits and Coverage (SBC) documents are subject to strict formatting and content requirements established by federal regulators. SBCs must use a standardized template and are intended to present plan information in a uniform, comparable format across all issuers and employers.
As a result, SBCs may not include agency or broker logos, marketing language, or promotional content. The layout, font size, order of information, and required headings may not be altered. Only plan-specific data, such as deductibles, cost-sharing amounts, and covered services, may be customized within the confines of the federal template.
Limited identifying information is permitted in designated areas of the SBC. This may include contact information for the plan administrator, insurer, or employer, but it is intended solely to help participants obtain additional information or ask questions. It is not intended to function as branding, advertising, or co-marketing.
If additional explanations, branding, or plan summaries are desired, they must be provided in separate materials. Those materials cannot replace the official SBC and must not be presented in a way that modifies or obscures the required SBC content.
Sources
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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 -
U.S. Department of Labor, SBC Templates and Instructions
https://www.dol.gov/agencies/ebsa/laws-and-regulations/laws/affordable-care-act/for-employers-and-advisers/sbc-template -
Affordable Care Act, Section 2715
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29 CFR §2590.715-2715
Content history
Originally published: June 16, 2025
Last reviewed: January 25, 2026