Key Q4 Compliance Deadlines for 401(k) and Other Defined Contribution 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
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)
Furnish a Summary Annual Report to each participant and to each beneficiary receiving benefits under the plan
Summary Annual Report
(29 C.F.R. § 2520.104b-10)
At least once each calendar quarter , with regard to each participant or beneficiary who has the right to direct investments of the assets in their account under the plan
Provide the required statements to participants and beneficiaries New for 2026: At least one benefit statement each calendar year must be furnished on paper in written form, unless an exception under ERISA § 105(a)(2)(E) applies. Note: The DOL issued Field Assistance Bulletin 2026-02 indicating temporary "good faith" compliance relief for 2026.
AND
At least once each calendar year , with regard to each participant or beneficiary who has their own account under the plan but does not have the right to direct investments of assets in their account
Periodic Benefit Statement
(ERISA § 105(a))
AND
Upon a written request , with regard to a plan beneficiary not described above (each individual is limited to one request per 12- month period)
If you opt to use this alternative method , provide each “unenrolled participant” (any employee who is eligible to participate in the plan but has not yet enrolled) with an annual notice of their eligibility to participate and any applicable election deadlines, in accordance with all requirements under ERISA § 111 and IRC § 414(bb)
Annual Reminder Notice for Unenrolled Participants
During the plan’s annual open season election period
(ERISA § 111 and IRC § 414(bb))
OR
Note: This notice is required only if it is used as an alternative to providing unenrolled participants periodic disclosures, notices, or plan documents as otherwise required.
Within a “reasonable period” before the next plan year begins , if there is no annual open season election period
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