As a reminder to all San Francisco employers that, if a business is covered by the San Francisco Health Care Security Ordinance (HCSO) and/or the Fair Chance Ordinance (FCO), the business must submit the 2025 Employer Annual Reporting Form (ARF) no later than Friday, May 1, 2026, or be subject to a penalty of $500 per quarter.

What Employers Need to Do

• Confirm Coverage (Any 2025 Quarter): Coverage depends on workforce size, San Francisco business registration, and having at least one employee working eight (8) or more hours per week in San Francisco.

• Assemble Data (by Quarter) before starting—the online form may not save in progress:
  • Total headcount.
  • Number of HCSO‑covered employees.
  • Employer health care expenditures by type (e.g., insurance contributions, San Francisco City Option, HRA/HSA).
  • Number of employees hired to work in San Francisco.
  • Whether background checks were conducted for San Francisco–based roles.
  • Whether any candidates with conviction histories were hired.

• Locate or Obtain the seven (7) ‑digit Business Account Number (BAN) and register or update with the San Francisco Treasurer and Tax Collector if needed.

• If Self‑funded or using nonstandard coverage, verify 2025 HCSO top‑off calculations, and ensure payments due March 2, 2026, are reflected in totals.

• File Online Between April 1 and May 1, 2026. The portal closes at the deadline, and late electronic submissions are not accepted.

• Optional Training: Attend OLSE’s ARF filing webinar or watch the recording.

• Official Resources: consider attending OLSE’s ARF webinar (or watching the recording).

Overview

Important Dates

• Form Available: April 1, 2026 (online via SF.gov).
• Deadline to File: May 1, 2026; late or missing filings can trigger $500 per quarter penalties.
• Help From OLSE: A live ARF webinar will guide employers through the process (recording posted afterward) – Webinar Registration Link: ⁠FCO & HCSO Annual Reporting Form (ARF) Webinar.

Who Must File

• Employers must file if they were covered by either ordinance for any part of 2025.

• HCSO Coverage: For‑profit employers with 20 or more workers (anywhere) or nonprofits with 50 or more, who hold a San Francisco business registration and have at least one worker in San Francisco. Covered employees include those employed over 90 days and working eight (8) or more hours/week in San Francisco (with specific exemptions).

• FCO Coverage: Employers with five (5) or more employees located in or doing business in San Francisco; applies to positions that work eight (8) or more hours/week in San Francisco, including temporary, seasonal, contract/agency work, and paid or unpaid training.

What Is Reported (single, combined ARF)

• HCSO (2025 Data): Headcount by quarter; number of HCSO‑covered employees by quarter; total employer health care expenditures and types of spending (e.g., insurance contributions, San Francisco City Option, qualifying HRA/HSA).

• FCO (2025 Data): Number of employees hired to work in San Francisco; whether background checks were performed; whether individuals with conviction histories were hired.

How to File

• Where: Online ARF on SF.gov (linked from OLSE’s HCSO page when live).

• Business Account Number: A seven (7) ‑digit San Francisco Business Account Number (BAN) is required; if absent, employers must register with the San Francisco Treasurer & Tax Collector before filing. Because the form may not allow saving progress mid‑session, employers should gather all required data before beginning.

• After the Deadline: Once the portal closes, there is no late electronic submission. Plan internal cutoffs ahead of time.

Why this matters

Submitting the ARF confirms compliance with both HCSO and FCO in one filing and avoids per‑quarter penalties. For employers with self‑funded plans, any 2025 “top‑off” owed for minimum spending (due March 2, 2026) affects final HCSO totals—this should be reconciled before filing.

Key Risks for Employers

• Misjudging Coverage: Multi‑state employers must count all employees worldwide to determine HCSO coverage, but spending/reporting apply only to hours worked in San Francisco.

• Portal Timing: Relying on late filing after portal closure can result in no electronic submission path and automatic penalties.

• Data Readiness: Starting the ARF without complete data can derail submission because the form does not allow saving a draft.

Source References:

• San Francisco – Health Care Security Ordinance
• San Francisco – Fair Chance Ordinance 

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