Key Q4 Compliance Deadlines for 401(k) and Other Defined Contribution Plans*
Deadline
Requirement
Action Item
Quarterly Disclosures Related to Administrative and Individual Expenses Actually Charged
Provide required disclosures to each participant and beneficiary
At least once in any three-month period
(29 CFR § 2550.404a-5)
Annual Disclosures of Plan- Related Information, Investment-Related Information, andAdministrative and Individual Expenses That May Be Charged
At least “annually” (at least once in any 14-month period)
Provide required disclosures to each participant and beneficiary
(29 CFR § 2550.404a-5)
AUTOMATIC-ENROLLMENT PLANS ONLY
Deadline
Requirement
Action Item
Provide required notice to each participant who is subject to the ACA for the applicable plan year (may be combined with the annual QDIA Notice or the annual Safe Harbor Notice, as applicable)
Annual Automatic Contribution Arrangement (ACA) Notice – ACA Plans Only
Within a “reasonable period” before the 2027 plan year begins; for example, December 2
(ERISA § 514(e)(3))
Annual Eligible Automatic Contribution Arrangement (EACA) Notice – EACA Plans Only
December 1, 2026 (or sooner, if necessary to give participants a “reasonable period of time” to opt out or change the level of default EACA contributions for the 2027 plan year – but no sooner than October 2, 2026)
Provide required EACA Notice to each participant subject to the EACA for the applicable plan year
(IRC § 414(w)(4))
December 1, 2026 (or sooner, if necessary to give participants a “reasonable period of time” to elect changes to the automatic contribution and/or investment for the 2027 plan year – but no sooner than October 2, 2026)
Annual Qualified Automatic Contribution Arrangement (QACA) Notice
Provide an annual QACA Notice to each participant subject to the QACA for the applicable plan year
(IRC § 401(k)(13)(E))
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