Key Q4 Compliance Deadlines for Defined Benefit Plans*
ANNUAL AND PERIODIC
Deadline
Requirement
Action Item
Form 5500 (or Form 5500- SF, as applicable) (IRC § 6058(a) and ERISA §§ 104, 4065)
Complete and file Form 5500/Form 5500-SF (and any required schedules and attachments) electronically using the DOL’s EFAST2 system Furnish a Summary Annual Report to each participant and to each beneficiary receiving benefits under the plan Ensure required statement is timely provided (or, in lieu of meeting the triennial requirement, provide the “alternative notice” described under ERISA § 105(a)(3)(A) at least once each year) New for 2026: These benefit statements (but not the alternative notices) must be furnished on paper in written form, unless an exception under ERISA § 105(a)(2)(E) applies.
October 15, 2026 (for the 2025 plan year), if a Form 5558 filing extension was obtained (otherwise, the deadline was July 31, 2026)
December 15, 2026 (for the 2025 plan year), if a Form 5558 filing extension was obtained (otherwise, the deadline was September 30, 2026)
Summary Annual Report (29 C.F.R. § 2520.104b-10)
At least once every 3 years (does not necessarily have to be during Q4), with regard to each participant who has a nonforfeitable accrued benefit and is employed by the employer maintaining the plan at that time
Periodic Benefit Statement (ERISA § 105(a)(1)(B))
Note: ERISA § 105(a)(3) provides limited relief for defined benefit plans, including an alternative notice option
AND
Upon a participant or beneficiary’s written request (each individual is limited to one request per 12-month period)
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