PBGC Updates Premium Deadlines for 2025 and Beyond

The Pension Benefit Guaranty Corporation (PBGC) has announced a key change affecting premium payment deadlines for pension plans beginning in 2025 and later. Due to the Bipartisan Budget Act of 2015 (BBA 2015), plan sponsors must submit premium payments one month earlier than before.

Key Changes to Premium Deadlines

New Filing Deadline

• For plan years beginning in 2025, the premium due date is now the 15th day of the ninth month following the start of the plan year.
• Example: A plan starting January 1, 2025, now has a premium deadline of September 15, 2025, instead of October 15 under the previous rule.

Exceptions & Special Rules

• The change does not override PBGC’s disaster relief guidelines or adjustments for deadlines falling on weekends or federal holidays.
• Plan administrators should disregard previous PBGC payment regulations and refer to updated deadlines on the PBGC website.

Potential Repeal of Section 502

Ongoing Efforts to Reverse the Rule

• For eight consecutive years, presidential budget proposals have pushed to repeal Section 502 of BBA 2015, citing unnecessary administrative burdens for plan sponsors.
• The fiscal year 2025 budget calls this repeal "urgent," but as of now, the rule remains in effect.
• If Congress repeals the provision, PBGC will update premium filing instructions and notify practitioners as soon as possible.

Next Steps for Plan Sponsors

• Verify new premium deadlines for 2025 plan years and adjust filing processes accordingly.
• Monitor PBGC updates for possible legislative changes that could impact future deadlines.
• Stay informed on new premium filing instructions, expected to be released soon.

Plan sponsors should prepare for earlier premium payments while staying alert for potential regulatory changes that may impact filing requirements.