PBGC Issues Technical Update on Accelerated Due Date for 2025 Premium Filings

The Pension Benefit Guaranty Corporation (PBGC) has issued its first technical update of the year to provide guidance on the accelerated premium filing date for plan years that begin in 2025.

As required by a provision in the Bipartisan Budget Act of 2015, for plan years that begin in 2025, the PBGC premium filing due date for all plans is the 15^th day of the 9^th calendar month that begins on or after the first day of the plan year. This is a change from the normal due date under the PBGC regulations, which is the 15^th day of the 10^th calendar month that begins on or after the first day of the plan year. The provision also supersedes the special due dates that typically apply for certain new plans and plans that complete a standard termination before the normal premium due date.

In practice, this means that for calendar-year plans, in 2025 the PBGC premium filing is due on September 15, instead of October 15. For ease of reference, the PBGC has included a chart of plan year beginning dates and premium due dates in the technical update and will also include the due dates in the premium filing instructions for 2025.

The accelerated premium filing date only applies to plan years that begin in 2025, and the PBGC has noted that there have been calls to repeal the provision that requires it. If Congress does repeal the provision, the PBGC will issue additional guidance. However, for now the accelerated premium filing date schedule remains effective.

We will continue to monitor this topic as the year progresses.

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About Author: Summer Conley

Summer Conley is leader of the firm's benefits and executive compensation group. She guides companies through the complicated legal landscape surrounding employee benefits. She advises on qualified plan, health and welfare and executive compensation issues. View all posts by Summer Conley and Kristina Ferris Salamoun

About Author: Kristina Ferris Salamoun

Kristina F. Salamoun counsels clients who provide qualified health and retirement plans on plan design and administration. Kristina assists benefit plan clients with compliance with ERISA, the Internal Revenue Code and other applicable laws, including COBRA, HIPAA, PPACA and SECURE Act. She advises plan sponsors and administrators on fiduciary matters and various government reporting and filing requirements. Kristina also negotiates and reviews service-provider contracts for employee benefit plans and drafts key documents such as summary plan descriptions, plan and trust amendments, and plan policies. In addition, she manages client responses to government investigations, and provides advice on the review of qualified domestic relations orders (QDROs), power of attorney documents, subpoenas and subrogation matters. View all posts by Summer Conley and Kristina Ferris Salamoun