Key Q4 Compliance Deadlines for Defined Benefit Plans*
PLANS WITH DEFERRED VESTED PARTICIPANTS (applicable only if plan subject to the vesting standards of ERISA § 203)
Deadline
Requirement
Action Item
Form 8955-SSA
(IRC § 6057(a))
Note: This reporting requirement applies only with regard to plan years in which one or more participants separated from service covered by the plan with a deferred vested benefit under the plan. Forms due in 2026 for the 2025 plan year must report participants who separated from service during the 2024 plan year, are entitled to vested benefits, and have not previously been reported, if any. Participants who separated from service during the 2025 plan year and are entitled to deferred vested benefits may also be reported on the 2025 plan- year form.
October 15, 2026 (for the 2025 plan year), if a Form 5558 filing extension was obtained (otherwise, the deadline was July 31, 2026) Note: The 2026 filing deadline applies with regard to participants who separated from service covered by the plan during the 2024 plan year (if any) and are required to be reported on Form 8955-SSA (though deferred vested participants who separated from service during the 2025 plan year may also be included).
Complete and file Form 8955- SSA with the IRS either electronically (mandatory for some plans) or on paper
Individual Statement to Separated Participants With Deferred Vested Retirement Benefits
Furnish an individual statement (as described in IRC § 6057(e)) to each deferred vested participant reported on the Form 8955-SSA for the applicable plan year(s)
Same as above
(IRC § 6057(e)) and ERISA §105(c))
PBGC-COVERED PLANS ONLY
Deadline
Requirement
Action Item
Submit required premium payment and filing electronically through PBGC’s online filing website (My PAA). New for 2026: The paper check payment option is no longer available.
PBGC Premium Payment and Comprehensive Premium Filing (ERISA §§ 4006-4007 and PBGC’s Premium Regulations)
October 15, 2026
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