2025 ERISA Plan Compliance Calendar

2025 ERISA Plan Compliance Calendar

A schedule to help plan sponsors track important due dates for their plan

The dates below are an overview of important regulatory dates for 2025. This document does not identify all compliance obligations or due dates. The dates in the examples below are based on a January plan year. If you operate your plan using a different plan year, the same rules apply, but the deadline dates vary accordingly based on the start of your plan year.

January


31

  • Deadline for plan providers to issue Form 1099-R to participants who received distributions during the previous calendar year.

February


14

  • Deadline to provide participant-directed defined contribution (DC) plan participants with the quarterly benefit/disclosure statement and statement of plan fees and expenses actually charged to the individual plan accounts during the last quarter of 2024. Note: This is due 45 days after quarter-end.

28

  • Deadline for plan providers to file Form 1099-R with the Internal Revenue Service (IRS) to report distributions that were made to plan participants in the previous calendar year.

March


15

  • Deadline for processing corrective distributions for Non-Safe Harbor plans, without imposition of a 10% excise tax, to remedy a failed Actual Deferral Percentage (ADP)/Actual Contribution Percentage (ACP) test of the prior year.
  • Deadline for filing S corporation, LLC or partnership tax returns, and contribution deadline for deductibility (without extension) for companies and partnerships operating on a calendar-fiscal-year basis.
  • Waiver of the minimum funding standard for money purchase pension plans application is due to the IRS.

31

  • Deadline for electronic filings of Form 1099-R for 2024 distributions to the IRS.

April


1

  • For participants who turned 73 years old or terminated employment (whichever is later) in 2024, the initial Required Minimum Distribution (RMD) is due to those participants.

15

  • Deadline for processing corrective distributions to participants whose contributions in the prior calendar year exceeded the applicable limit under Section 402(g) of the IRC.

  • Deadline for filing C corporation, sole proprietor and individual tax returns and contribution deadlines for deductibility (without extension).


Note: When the due date for filing an IRS or Department of Labor form falls on a Saturday, Sunday or legal holiday, the deadline is generally extended to the next business day.

May


15

  • Deadline to provide participant-directed DC plan participants with the quarterly benefit/disclosure statement and statement of plan fees and expenses actually charged to the individual plan accounts during the first quarter of this year. Note: This is due 45 days after quarter-end.

June


30

  • Deadline for processing corrective distributions, without imposition of a 10% excise tax, resulting from an ACP test failure of the prior year by a plan with an EACA.

July


29

  • Deadline for distributing any required Summary of Material Modification resulting from a plan amendment adopted during the previous Plan Year.

31

  • Deadline for filing Form 5330 (Return of Excise Taxes Related to Employee Benefit Plans) for reporting and paying excise taxes on both prohibited transactions and plan contributions that occurred in the previous calendar year.

  • Deadline to file Form 5500 for ERISA Employers* (without an extension).
    *For ERISA Employers, deadline to file Form 5558 requesting an automatic extension to permit the filing of Form 5500 up to 2½ months later (i.e., October 15).

August


14

  • Deadline to provide participant-directed DC plan participants with the quarterly benefit/disclosure statement and statement of plan fees and expenses actually charged to the individual plan accounts during the second quarter of this year. Note: This is due 45 days after quarter-end.

September


15

  • Due date for money purchase pension plans to make required contributions to their plan trust, i.e., by 8½ months after the plan year-end.
  • If an S corporation or partnership plan sponsor filed a corporate tax extension, this is the deadline to make employer profit-sharing and matching contributions for the 2024 tax year.

  • For ERISA Employers, deadline for distributing the Summary Annual Report (SAR) to participants if Form 5500 was filed by the July 31 deadline.

30

  • Deadline to provide participants with the SARs from plans with a December 31 year-end, i.e., due nine months after the plan year-end or two months after filing the Form 5500 (unless the Form 5500 filing deadline is extended).

October


15

  • Deadline for adopting a retroactive amendment to correct an IRC Section 410(b) coverage or Section 401(a)(4) non-discrimination failure for the prior calendar year.
  • Deadline to provide the IRS with the Form 5310-A to give notice of the establishment of qualified separate lines of business.
  • For ERISA Employers, extended deadline for filing Form 5500.

November


14

  • Deadline to provide participant-directed DC plan participants with the quarterly benefit/disclosure statement and statement of plan fees and expenses actually charged to the individual plan accounts during the third quarter of this year. Note: This is due 45 days after quarter-end.

15

  • If the Form 5500 deadline was extended due to a corporate tax filing extension, the SARs are due to the plan participants.

December


1

  • Deadline for sending annual automatic contribution arrangement notice to participants who are being automatically enrolled or have previously been automatically enrolled and have not yet made an affirmative contribution and/or allocation election.
  • Deadline for sending annual 403(b) and 401(k) Safe Harbor notices to participants if applicable to the plan.
  • For ERISA Employers, deadline for sending annual Qualified Default Investment Alternative notice to participants who are being enrolled with a default investment allocation election or have been previously enrolled with a default investment allocation and have not yet made an affirmative allocation election.

15

  • Deadline to provide participants with SARs if the Form 5500 deadline was extended as a result of filing the Form 5558.

31

  • Deadline for an existing DC plan to convert to a safe harbor plan and also the deadline for a safe harbor plan to remove its safe harbor status for the following year.

  • Due date to adopt discretionary amendments to the plan, subject to certain exceptions,
    i.e., anti-cutbacks.
  • Deadline to correct a failed ADP/ACP test.
  • Final date to elect safe harbor status for the prior plan year with a non-elective contribution of 4% or more of compensation.
  • Deadline for 2025 RMDs.
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