COBRA Notice Deadlines: Who Sends What, and When

9/11/2026

COBRA notice deadlines run in a fixed sequence: a general notice within 90 days after plan coverage begins, an employer notice to the plan administrator within 30 days of a qualifying event, and an election notice from the administrator within 14 days after that (44 days in total when the employer administers the plan itself). Qualified beneficiaries have their own 60-day deadline to report divorce, legal separation or a child losing dependent status. Each clock starts from a different trigger, and most notice failures come from starting one from the wrong date.

The COBRA Notice Timeline at a Glance

Notice	Who sends it	Deadline	Clock starts
General (initial) notice	Plan administrator	90 days	Date plan coverage begins
Notice of qualifying event	Employer	30 days	Termination, reduction in hours, death or Medicare entitlement
Election notice	Plan administrator	14 days	Administrator receives notice of the event
Election notice (employer is administrator)	Employer	44 days	The qualifying event (or loss of coverage, if the plan measures from that)
Notice of divorce, separation or loss of dependent status	Employee or qualified beneficiary	60 days	The event (or later loss of coverage, depending on plan terms)
Notice of unavailability	Plan administrator	Same window as the election notice	Receipt of a notice or request that does not qualify
Notice of early termination	Plan administrator	As soon as practicable	Decision that coverage will end early

The General Notice: 90 Days

The general notice explains COBRA rights before anyone needs them. It must reach each covered employee, and each covered spouse, within 90 days after their coverage under the plan begins. A single mailing addressed to both the employee and spouse at the same address is generally acceptable when they live together; a spouse at a different address needs a separate notice.

The deadline is tied to each person's coverage start, so it recurs whenever someone new joins the plan, including a spouse added at a life event. It also matters later: the general notice is where beneficiaries learn that they must report divorce and dependent status changes. A plan that never sent it has a hard time enforcing the beneficiary's 60-day deadline.

Employer Notice to the Administrator: 30 Days

When the employer and plan administrator are separate, as with an insurer or third-party administrator, the employer must tell the administrator within 30 days about qualifying events that it is in a position to know about: termination of employment, reduction in hours, the employee's death and the employee's Medicare entitlement.

By default the 30 days run from the qualifying event. A plan may measure from the date coverage is lost instead, if the plan document says so. Know which rule your plan uses, because a reduction in hours and the resulting loss of coverage can fall in different months.

This handoff is the step that fails most often. It depends on payroll or HR noticing that an event has happened, and a reduction in hours does not generate an exit checklist the way a termination does.

Election Notice: 14 Days, or 44 Days in Total

Once the administrator is told about a qualifying event, it has 14 days to send the election notice to each qualified beneficiary. Where the employer is its own plan administrator, the two steps merge and the employer generally has 44 days from the qualifying event (or loss of coverage, if the plan uses that measure).

The election notice starts the beneficiary's election period, which runs at least 60 days from the later of loss of coverage or the date the notice is provided. The rules for that period and the premium deadlines that follow are covered in COBRA election and payment rules, so they are not repeated here.

Beneficiary Notices: 60 Days

Some qualifying events are invisible to the employer. For divorce, legal separation and a child ceasing to be a dependent, the covered employee or qualified beneficiary must notify the plan administrator within 60 days. A plan cannot make that window end sooner than 60 days after the latest of the event, the date coverage would be lost, or the date the beneficiary was told about the obligation through the summary plan description or general notice.

Two other beneficiary notices run on similar clocks:

Disability determination. To get the 11-month disability extension, the beneficiary must provide notice of a Social Security disability determination within 60 days after the determination and before the initial 18 months end.
Second qualifying event. A spouse or dependent who has a second qualifying event during an 18-month continuation period must notify the plan within 60 days to extend coverage.

The plan can enforce these deadlines only if its procedures for giving notice are described in the summary plan description and the general notice. If a plan has no reasonable procedure, a beneficiary's informal notice may count.

Notice of Unavailability

When the administrator receives a notice or election that it decides does not qualify, such as a beneficiary report that arrives after the 60-day window, it must send a notice explaining why COBRA is not available. The deadline mirrors the election notice window. This notice is widely overlooked because nothing on the administrator's side changes, but a silent denial is still a denial without notice.

Notice of Early Termination

If continuation coverage ends before the maximum period, the administrator must send a notice as soon as practicable after deciding to end it, stating the reason, the date coverage ends and any rights to other coverage. The permitted grounds are covered in when an employer can terminate COBRA coverage, and the content of the notice in notice requirements for terminating COBRA.

How Deadlines Get Missed

Counting from the wrong trigger. Starting the election-notice clock at the termination date when the administrator was told later, or vice versa.
Late employer handoff. A last-day-of-month termination processed in the next payroll cycle can use half the 30 days before anyone acts.
No reduction-in-hours trigger. The event happens, the notice never does.
Treating the family as one notice. Each qualified beneficiary is entitled to the election notice.
No proof of mailing. The plan must be able to show a specific notice was sent on a specific date to the last known address.

Build every deadline into a calendar with a named owner, and record the send date and method in each beneficiary's file. Our COBRA compliance checklist puts these steps in order.

Frequently Asked Questions

Are COBRA notice deadlines counted in calendar days or business days?

Calendar days. Weekends and holidays are included, which is why a month-end termination can leave very little working time.

Can the employer and administrator split the 44 days differently?

The 44-day combined period applies where the employer is the administrator. Where they are separate, the employer has 30 days and the administrator 14, and each is responsible for its own step.

Does sending the election notice by mail satisfy the deadline?

First-class mail to the last known address is the common method, and the notice is treated as provided when sent. Keep evidence of the mailing date.

What if a beneficiary reports a divorce after 60 days?

If the plan's notice procedures were properly communicated, the plan can deny continuation for the spouse, but it must send a notice of unavailability.

Do state mini-COBRA laws use the same deadlines?

Not necessarily. State continuation laws set their own notice periods and often run through the insurer, so check each state that applies to an insured plan.