On January 6, 2025, the Pension Benefit Guaranty Corporation issued Technical Update 25-1, lending guidance on the timing of premium payments for all 2025 Plan Years.
Per Section 502 of the Bipartisan Budget Act of 2015, the premium filing due date for all plans is the 15th day of the ninth calendar month that begins on or after the first day of the plan year. This means that for all 2025 plan years, premium payments are due one month earlier than the ‘Normal Premium Due Date’ (e.g. for calendar year plans, September 15, 2025, rather than October 15, 2025). This updated schedule applies to single and multiemployer plans for the 2025 plan year only, and the premium due date will default to its normal schedule in 2026.
There are certain exceptions in which premium filings are due on a different date than the revised timeline specifies – examples of this include new plans adopted during 2025 and are effective fewer than 90 days before the Normal Premium Due Date, terminated plans effective before the Normal Premium Due Date, and plans that were impacted by disasters. For additional guidance on special exceptions, refer to § 4007.11(b), (c), and (d) of PBGC’s Payment of Premium regulation.
Revised Filing Dates
The table below details the revised filing dates for the 2025 plan year:
| Date Plan Year Begins | Due Date |
|---|---|
| 1/1/2025 | 9/15/2025 |
| 1/2/2025 – 2/1/2025 | 10/15/2025 |
| 2/2/2025 – 3/1/2025 | 11/17/2025* |
| 3/2/2025 – 4/1/2025 | 12/15/2025 |
| 4/2/2025 – 5/1/2025 | 1/15/2026 |
| 5/2/2025 – 6/1/2025 | 2/16/2026* |
| 6/2/2025 – 7/1/2025 | 3/16/2026* |
| 7/2/2025 – 8/1/2025 | 4/15/2026 |
| 8/2/2025 – 9/1/2025 | 5/15/2026 |
| 9/2/2025 – 10/1/2025 | 6/15/2026 |
| 10/2/2025 – 11/1/2025 | 7/15/2026 |
| 11/2/2025 – 12/1/2025 | 8/17/2026* |
| 12/2/2025 – 12/31/2025 | 9/15/2026 |
* Dates adjusted to the next business day if the due date falls on a weekend of federal holiday.
According to the update, it is possible that Section 502 of the Bipartisan Budget Act of 2015 will be repealed during federal fiscal year 2025. For the last eight years, the President’s Budget has called for the repeal of the section due to unnecessary costs and other burdens that plan sponsors may incur as a result of the accelerated timeline. If it is repealed, practitioners will be notified by the PBGC and the filing instructions will be revised promptly.
Author: Carley Appleby | [email protected]
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For more information on this topic, please contact a member of Withum’s Multiemployer Benefit Plans Services Team.
