PBGC Premium Filing Deadlines Shift for 2025: What You Need to Know

On January 6, 2025, the Pension Benefit Guaranty Corporation (PBGC) issued Technical Update 25-1 addressing the timing of premium filings and premium payments for the plan years beginning in 2025. 

Historically for most plans, the premium filing for a plan is due by the 15th day of the 10th calendar month of the plan year. For a plan year beginning on January 1st, this due date is October 15th, unless the 15th falls on a weekend or federal holiday, in which case the due date is adjusted to the first business day following the 15th. 

A provision in the Bipartisan Budget Act of 2015 changes the due date for premium filings for plan years beginning in 2025 to be the 15th day of the 9th calendar month of the plan year. For a plan year beginning on January 1, 2025, the PBGC filing is due on September 15, 2025. For plan years beginning in 2026, the due date for premium filings will again be the 15th day of the 10th calendar month of the plan year. 

The following chart illustrates the revised due dates for 2025 premium filings: 

*The 15th day of ninth month beginning on or after the first day of the plan year falls on a weekend or federal holiday. 

For several years, the President’s Budget has advocated for the repeal of this provision. However, it remains in effect. If the provision is repealed, PBGC will promptly update the filing due dates. 

For plans that have no PBGC unfunded vested benefits, the impact of this change will simply be to accelerate the due date of the filing and premium by one month. For plans with PBGC unfunded vested benefits, the due date of the filing is now the same as the final due date for contributions. This may require sponsors to accelerate the timing of their final contribution so these amounts can be properly reflected in the PBGC filing, in addition to accelerating the due date of the filing and premium by one month. 

 The information provided in this blog post is for informational purposes only and should not be considered as financial, legal, or professional advice. Always consult with a qualified professional for specific advice tailored to your individual circumstances.