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Compliance Deadlines for Retirement & Welfare Benefit Plans

Employer Guide to Q4 2026 Compliance Deadlines for Retirement and Welfare Benefit Plans

EMPLOYER GUIDE TO Q4 2026 COMPLIANCE DEADLINES		1
The fourth quarter is an important time for employers and plan administrators to take stock of their employee benefit plans and prepare for the year ahead.		3
In addition to recurring year-end administrative tasks, Q4 brings a wave of compliance deadlines for employer-sponsored retirement and health plans. Missing a deadline can result in additional administrative work, potential penalties, and other negative consequences (such as losing a plan’s safe harbor status) – so we created this Employer Guide to help you keep track of it all.		3
We will continue to monitor developments in this area and provide updates as warranted, so make sure you are subscribed to the Fisher Phillips Insight System to receive the latest developments straight to your inbox. If you have any questions, contact your Fisher Phillips attorney, the author of this Insight, or any attorney in our Employee Benefits and Tax Practice Group.		3
Key Q4 Compliance Deadlines		4
for 401(k) and Other Defined Contribution Plans*		4
*This chart is for single employer, private sector plans subject to ERISA that use a calendar-year plan year.		4
It covers annual and periodic notice and reporting requirements; it generally does not cover initial or		4
event-based notice or reporting requirements.		4
2026 ONLY		4
Deadline		4
Requirement		4
Action Item		4
Key Q4 Compliance Deadlines for 401(k) and		8
Other Defined Contribution Plans*		8
TRADITIONAL SAFE HARBOR 401(K) PLANS ONLY		8
Deadline		8
Requirement		8
Action Item		8
December 1, 2026		8
Key Q4 Compliance Deadlines for Defined Benefit Plans*		9
*This chart is for private-sector, single-employer defined benefit plans that are subject to ERISA and that use a		9
calendar-year plan year. It covers annual and periodic notice and reporting requirements with deadlines that fall		9
(or could fall) within Q4; it generally does not cover initial or event-based requirements.		9
2026 ONLY		9
Deadline		9
Requirement		9
Action Item		9
December 31, 2026		9
Key Q4 Compliance Deadlines for		11
Defined Benefit Plans*		11
PLANS WITH DEFERRED VESTED PARTICIPANTS		11
(applicable only if plan subject to the vesting standards of ERISA § 203)		11
Deadline		11
Requirement		11
Action Item		11
(IRC § 6057(e)) and ERISA §105(c))		11
PBGC-COVERED PLANS ONLY		11
Deadline		11
Requirement		11
Action Item		11
Key Q4 Compliance Deadlines		12
for Employer-Sponsored Group Health Plans*		12
*This chart is for private-sector, employer-sponsored group health plans that are subject to ERISA		12
and use a calendar-year plan year. It covers annual and periodic notice and reporting requirements that fall (or could fall) within Q4; it generally does not cover initial, event-based, or “upon request” requirements.		12
Deadline		12
Requirement		12
Action Item		12
Note: This is the deadline for the annual notice only; other distribution timing requirements apply.		12
(42 CFR § 423.56(c))		12
Note: This requirement generally applies to group health plans that offer prescription drug coverage, subject to limited exceptions.		12
Note: Group health plans subject to the Part D disclosure rules also must submit an annual disclosure to CMS regarding creditable coverage status of their prescription drug plan. This annual disclosure must be submitted online by March 2 of the applicable plan year. Learn more here.		12
Key Q4 Compliance Deadlines for Defined Benefit Plans*		12
*This chart is for private-sector, single-employer defined benefit plans that are subject to ERISA and that use a		12
calendar-year plan year. It covers annual and periodic notice and reporting requirements with deadlines that fall		12
(or could fall) within Q4; it generally does not cover initial or event-based requirements.		12
2026 ONLY		12
Deadline		12
Requirement		12
Action Item		12
December 31, 2026		12
Extended deadline to amend qualified plans for certain required and discretionary amendments, including under the SECURE Act, CARES Act, and SECURE 2.0 Act		12
(IRS Notice 2024-2)		12
Ensure plan is properly amended for any applicable required amendments. Discretionary amendments implementing SECURE, CARES, or SECURE 2.0 provisions may be adopted by December 31, 2026, even if operationally implemented in prior years.		12
JENNIFER S. KIESEWETTER		14
KATIE		14
REYNOLDS		14

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