Key Q4 Compliance Deadlines for 401(k) and Other Defined Contribution 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.
Complete and file Form 8955- SSA with the IRS either electronically (mandatory for some plans) or on paper
October 15, 2026 (for the 2025 plan year), if a Form 5558 filing extension was obtained (otherwise, the deadline was July 31, 2026)
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)
Individual Statement to Separated Participants With Deferred Vested Retirement Benefits
Same as above
PARTICIPANT-DIRECTED PLANS ONLY
Deadline
Requirement
Action Item
December 1, 2026 (or sooner if necessary to provide a “reasonable period of time” before the 2027 plan year begins) Note: If the QDIA Notice is combined with an EACA, QACA, or Safe Harbor 401(k) Notice (see below), it must also comply with the timing requirements for those notices.
Provide required annual QDIA notice to participants and beneficiaries on whose behalf an investment in a QDIA may be made (may be combined with an EACA, QACA, or Safe Harbor 401(k) Notice)
Annual Qualified Default Investment Alternative (QDIA) Notice (29 C.F.R. § 2550.404c- 5(c)(3)(ii))
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