Key Takeaways:

• Stay compliant with ERISA by tracking key 2025 deadlines for retirement plans.
• Be aware of critical contribution limits and participant notices.
• Conduct mid-year testing to address compliance risks early.

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As you work to maintain compliance with your defined benefit or defined contribution retirement plan in 2025, keep the following deadlines and other important dates in mind. Dates assume a calendar year plan. Some deadlines may not apply, or dates may shift based on the plan sponsor’s fiscal year.

2025 Employee Retirement Income Security Act (ERISA) Dates to Know

JANUARY 15
Fund: Possible fourth quarter 2024 contribution due for defined benefit pension plans.

JANUARY 31
Action: File IRS Form 945, Annual Return of Withheld Federal Income Tax, for non-payroll income taxes, such as taxes withheld by retirement plans, during 2024.
Action: Distribute IRS Form 1099-R to participants for 2024 retirement plan distributions.

FEBRUARY 10
Action: File IRS Form 945 for 2024 non-payroll withholding if taxes were paid in full and deposited on time.

FEBRUARY 28
Action: File IRS Form 1096, Annual Summary and Transmittal of U.S. Information Returns, with IRS if using paper transmittal for 2024 tax year.
Action: File IRS Form 1099-R in paper format with the IRS for 2024 retirement plan distributions.

MARCH 15
Action: Highly compensated employees who fail ADP/ACP test for prior plan year must have refunds processed (other than eligible automatic contribution arrangements).
Fund: Partnerships and S Corporations that are not getting an extension must fund employer contributions to receive tax deduction for the prior year.

MARCH 31
Action: Electronic filing deadline for Form 1099-R.
Action: File IRS Form 5330 excise tax return and payment for excess 2023 ADP/ACP contributions.

APRIL 1
Action: 401(k) plans with publicly traded employer stock that follow Article 6A of the Regulation S-X (SEC format) must file Form 11-K with the Securities and Exchange Commission.
Action: Recordkeeper (or other responsible party) completes and files Form 1099-R electronically with the IRS for 2024 retirement plan distributions.
Action: Deadline for 5% business owners and terminated participants who turned 73 in 2023 to receive their required minimum distribution (RMD).

APRIL 15
Distribute: Possible first quarter 2025 contribution due for defined benefit pension plans.
Fund: Possible first quarter 2025 contribution due for defined benefit pension plans.
Distribute: Participants who contributed over 402(g) or 415 limits in the previous year must be refunded the excess amount.
Action: File PBGC Form 4010, Notice of Underfunding for single-employer defined benefit plans with more than $15 million aggregate underfunding.
Fund: C Corporations and Sole Proprietors that are not getting an extension must fund employer contributions to receive tax deduction for the prior year.
Fund: IRA contributions for the prior tax year must be funded.

APRIL 30
Action: Send annual funding notice to participants of single- and multi-employer defined benefit plans with over 100 participants.

MAY 15
Action: Start your mid-year compliance audit to ensure all records and documentation are up to date.

JUNE 29
Action: 401(k) plans with publicly traded employer stock must file SEC Form 11-K with the Securities and Exchange Commission or file an extension on SEC Form 12b-25.

JUNE 30
Action: Highly compensated employees who fail ADP/ACP test for prior plan year must have refunds processed, if an eligible automatic contribution arrangement (EACA).

JULY 14
Action: 401(k) plans with publicly traded employer stock that requested a 15-calendar day extension (SEC Form 12b-25) for the SEC Form 11-K must file the SEC Form 11-K with the Securities and Exchange Commission.

JULY 15
Fund: Possible second quarter 2025 contribution due for defined benefit pension plans.

JULY 31
Action: File IRS Form 5500, Annual Return/Report of Employee Benefit Plan, and IRS Form 8955-SSA, Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits, for the 2024 plan year.
Action: To request an extension of time to file IRS Form 5500, file IRS Form 5558.

SEPTEMBER 15
Fund: If an extension was filed, this is the deadline to fund employer contributions for Partnerships and S Corporations.
Fund: Last date to make 2024 contributions for single- and multi-employer defined benefit pension plans.

SEPTEMBER 30
Action: Distribute Summary Annual Report (SAR) to participants if Form 5500 was filed on July 31.
Action: File Form 5330 excise tax return for excess 2023 ADP/ACP contributions, if due date was extended by Form 8868.

OCTOBER 3
Action: Distribute annual notices to participants no earlier than October 3 and no later than December 2, including notices for: 2026 401(k) Plan Safe Harbor Match, Automatic Contribution Arrangement Safe Harbor, Automatic Enrollment, and Qualified Default Investment Alternatives (QDIA).

OCTOBER 15
Fund: Possible third quarter 2025 contribution due for defined benefit pension plans.
Action: Extended deadline for filing IRS Form 5500 and IRS Form 8955-SSA.
Action: Extended deadline for filing individual and C Corp tax returns.
Action: If an extension was filed, this is the deadline to fund defined contribution employer contributions for C Corporations and Sole Proprietors.
Action: Open a Simplified Employee Pension (SEP) plan for extended tax filers.
Action: Send annual funding notice to participants of single- and multi-employer defined benefit plans with 100 or fewer participants.
Action: Defined benefit plan PBGC Premium filings and payments due.

OCTOBER 31
Action: Single-employer defined benefit plans that are less than 60% funded or are 80% funded and have benefit restrictions triggered must inform participants by October 31 or 30 days after the benefit restriction applies.

DECEMBER 1
Action: Distribute annual participant notices no later than December 2 for the 2026 upcoming calendar year plan year. These include notices for: 401(k) Plan Safe Harbor Match, Automatic Contribution Arrangement Safe Harbor, Automatic Enrollment, and Qualified Default Investment Alternatives (QDIA).

DECEMBER 15
Action: Extended deadline to distribute Summary Annual Report (SAR) when Form 5500 was filed on October 15.

DECEMBER 31
Action: Final deadline to process corrective distributions for failed ADP/ACP testing; a 10% excise tax may apply.
Action: Ongoing required minimum distributions (RMDs) for 5% business owners and terminated participants must be completed.
Action: Amendments to change traditional 401(k) to safe harbor design, remove safe harbor feature or change certain discretionary modifications must be completed. Amendments to change to safe harbor non-elective design must be completed by December 1 of a given plan year for 3% or by December 31 of the following year for 4% contribution level.
Action: Plan sponsors must amend plan documents for any discretionary changes made during the year. Key Contribution Limits, Notices, and Best Practices for 2025 Retirement Plans

Plan sponsors should be aware of these critical contribution limits and participant notices for 2025:

• IRA contribution limits: The traditional and Roth individual retirement account (IRA)
  contribution limit is $7,000. A fixed catch-up contribution of $1,000 is available for
  participants aged 50 and older.
• 401(k), 403(b), and 457 deferral limits: Employee salary deferral limits are set at
  $23,500, with an additional catch-up contribution limit of $7,500 for participants aged
  50 and older.
• Maximum annual additions: Defined contribution plan account additions (including
  employee deferrals, employer contributions, and forfeitures) are capped at $70,000.
• Defined benefit plan limitations: The maximum annual benefit under Section
  415(b)(1)(A) is $285,000.
• Highly compensated employee threshold: Under Section 414(q)(1)(B), the dollar
  threshold to define “highly compensated employees” is $160,000.
• Summary plan descriptions (SPDs): Newly eligible employees must receive an SPD
  within 90 days of becoming covered by the plan.
• Participant communications:
  o Provide quarterly statements and fee disclosures to defined contribution plan
  participants.
  o Distribute annual lifetime income illustrations for defined contribution plans.
  

Best Practices for 2025 Compliance

• Provisions under SECURE 2.0: Collaborate with your service provider or MGO’s ERISA
  advisory team to address required and discretionary SECURE 2.0 provisions taking effect in 2025.
• Amendments: Execute discretionary amendments affecting plan design and
  administration promptly to meet IRS deadlines.
• Administrative alignment: Ensure administrative procedures align with the language in the plan document to prevent compliance issues.
• Mid-year compliance testing: Conduct mid-year testing to identify and resolve potential failures in annual compliance tests.
• Data accuracy: Validate the accuracy of the prior year’s census data with your
  recordkeeper. This data is critical for ADP/ACP testing and other plan operations.
• Compliance test review: Carefully review and approve testing results provided by the
  plan administrator to verify accuracy and alignment with plan rules.
  

By staying informed about these limits and implementing best practices, plan sponsors can
navigate compliance requirements effectively in 2025. For assistance, contact the MGO team today.