Note from BDO's ERISA Practice Leaders
Spring is here and BDO’s ERISA Center of Excellence is celebrating a fantastic first quarter along with National Employee Benefits Day on April 2nd.
In the past quarter, we’ve stuck to our resolutions to bring new insights and resources we hope you’ll find helpful – we updated our annual requirements calendar to help you stay on top of deadlines, best practices around remittance schedules and corrections programs, and more.
If you missed our annual Accounting, Audit, and Regulatory Updates Impacting Retirement Plans Webinar last month you can watch the recording here.
Staying current on ERISA topics is simplified with BDO: Follow along with our regular insights at our BDO ERISA Center of Excellence. Feedback on our content is always welcomed - you can reach us by emailing us.
Center of Excellence Blurb
BDO’s ERISA Center of Excellence is your source for insights on emerging regulations, industry trends, current topics, and more. Visit our Center of Excellence or follow along on Twitter: @BDO_USA and #BDOERISA.
In This Issue
- Hidden Figures: Why It’s Important for Plan Sponsors to Identify Controlled Groups
- What Form 11-K Filers Need to Know About the Upcoming Taxonomy Implementation
- IRS Issues First Guidance on Federal Income and Employment Tax for State Paid Family and Medical Leave Programs
- What Plan Sponsors Need to Know About the DOL’s Updates to the Voluntary Fiduciary Correction Program
2025 Deadlines and Important Dates
Sponsors of defined benefit and defined contribution retirement plans should keep the following deadlines and other important dates in mind as they work toward ensuring compliance for their plans in 2025. Dates assume a calendar year plan. Some deadlines may not apply, or dates may shift based on the plan sponsor’s fiscal year. For additional support, please contact your BDO representative.
April
- April 1: 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 by April 1.
- April 1: Recordkeeper (or other responsible party) completes and files Form 1099-R electronically with the IRS by April 1 for 2024 retirement plan distributions.
- April 1: April 1 deadline for 5% business owners and terminated participants who turned 73 in 2024 to receive their required minimum distribution (RMD).
- Note: the IRS “weekend rule” does not roll the April 1 deadline to the next business day if April 1 falls on the weekend or holiday
- April 15: Possible first quarter 2025 contribution due for defined benefit pension plans
- April 15: April 15 possible first quarter 2025 contribution due for defined benefit pension plans (i.e., contribute by April 15 before the weekend, as contribution deadlines are not extended to the next business day)
- April 15: Participants who contributed over 402(g) or 415 limits in the previous year must be refunded the excess amount by April 15.
- April 15: File PBGC Form 4010, Notice of Underfunding for single-employer defined benefit plans with more than $15 million aggregate underfunding by Monday, April 15
- April 15: C-Corporations and Sole Proprietors that are not getting an extension must fund employer contributions by April 15 to receive tax deduction for the prior year
- April 15: IRA contributions for the prior tax year must be funded by April 15.
- April 30: Send annual funding notice to participants of single and multi-employer defined benefit plans for over 100 participants by April 30.
May, June, and July
- May 15: Start your mid-year compliance audit to ensure all records and documentation are up to date.
- June 29: 401(k) plans with publicly traded employer stock must file SEC Form 11-K with the Securities and Exchange Commission by June 28 or file an extension on SEC Form 12b-25.
- June 30: Highly compensated employees who fail ADP/ACP test for prior plan year must have refunds processed by June 30, if an eligible automatic contribution arrangement (EACA).
- July 14: 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 by July 14.
- July 15: Possible second quarter 2025 contribution due for defined benefit pension plans by July 15
- July 31: 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 by July 31.
- July 31: To request an extension of time to file IRS Form 5500, file IRS Form 5558 by July 31.