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ARTICLE · 27 JANUARY 2025

PBGC Technical Update On Accelerated Premium Filing Due Dates For 2025

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As described in further detail below, absent Congressional action, plan sponsors should take note that PBGC premium filings will generally be due one month earlier than usual for plan years beginning in 2025.

United StatesEmployment and HR
Justin Alex
Justin Alex
Alex Scharr
Alex Scharr
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As described in further detail below, absent Congressional action, plan sponsors should take note that PBGC premium filings will generally be due one month earlier than usual for plan years beginning in 2025. This modification only applies for 2025.

Under ERISA Section 4007, the PBGC determines when premium filings—the submission of required data and payment of any required premiums for PBGC-insured plans—are due. Accordingly, PBGC Regulation Section 4007.11 provides that, in most cases, the premium filings for a plan year are due the "fifteenth day of the tenth calendar month that begins on or after the first day of the premium payment year."

However, Section 502 of the Bipartisan Budget Act of 2015 ("BBA of 2015") provides that, notwithstanding ERISA Section 4007 and the corresponding PBGC regulation, for plan years beginning in 2025 only, premium due dates are accelerated by one month to the "fifteenth day of the ninth calendar month that begins on or after

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