2024 ERISA Plan Compliance Calendar

A schedule to help plan sponsors track important due dates for their plan

The dates below are an overview of important regulatory dates for 2024. This document does not identify all compliance obligations or due dates. The dates in the examples below are based on a January plan year. If you operate your plan using a different plan year, the same rules apply, but the deadline dates vary accordingly, based on the start of your plan year.

January

16

Deadline for final minimum funding quarterly installment payment for defined benefit (DB) plans with a 2023 funding shortfall.

30

Deadline to provide participants and beneficiaries of a DB plan with the notice of benefit restrictions if the DB plan is less than 60% funded.

31

Deadline for sending Form 1099-R to participants who received distributions from a qualified retirement plan during the previous year.
Form 5500 is due to the DOL by January 31 for plans with a June 30 plan year-end (July plan years)—i.e., due seven months after plan year-end. The Form 5500 filing can be delayed to April 15 if the Form 5558 is filed with the IRS by this date.

February

14

Deadline for participant-directed defined contribution (DC) plans to provide participants with the quarterly benefit/disclosure statement and statement of plan fees and expenses actually charged to individual plan accounts during the last quarter of 2023.

28

Deadline for filing Form 1099-R with the IRS, if not filed electronically, to report distributions made in the previous year.

March

15

Deadline for distributing ADP/ACP refunds without incurring a 10% excise tax on the employer. A June deadline applies to plans satisfying the requirements of an Eligible Automatic Contribution Arrangement (EACA). (See June.)

Employer contributions are due to the retirement plan’s trust for S-corporations and partnerships with December 31 fiscal year-end to take deductions with no corporate tax extension.
Deadline to apply to the IRS for a waiver of the minimum funding standard for DB and money purchase pension plans.

31

Electronic filings of Form 1099-R for 2023 distributions are due to the IRS.

April

1

Initial required minimum distribution (RMD) is due to participants who turned 73 or terminated employment (whichever is later) in 2023.

15

Deadline for corrective distributions of excess deferral amounts under Internal Revenue Code Section 402(g) to participants.
Employer contributions are due to the plan’s trust for C-corporations with December 31 fiscal year-end to take deductions with no corporate tax extension.

29

Deadline for sponsors of single- and multi-employer DB pension plans to send their annual funding notice to participants, beneficiaries and labor organizations representing participants. Small plans— i.e., those covering fewer than 100 participants—must provide the notice by the IRS filing due date of the plan’s Form 5500; the notice takes the place of the summary annual report for a DB plan.

Note: The notice must be provided no later than 120 days after the close of the plan year, and 2024 is a leap year.

May

15

Deadline for participant-directed DC plans to supply participants with the quarterly benefit/disclosure statement and statement of plan fees and expenses actually charged to individual plan accounts during the first quarter of this year.

Note: Due 45 days after the end of the quarter.

June

30

Deadline for corrective distributions for failed ADP/ACP tests to highly compensated employees (HCEs), to avoid a 10% excise tax on the employer for EACA plans.

July

29

Summary of material modifications is due to participants—i.e., 210 days after the end of the plan year in which the change was adopted—unless it was included in a promptly updated Summary Plan Description (SPD).

31

Form 5330, which reports excise taxes related to employee benefit plans, is due to the IRS.
Form 5500 is due to the DOL for plans with a December 31 plan year-end (January plan years)—i.e., due seven months after year-end. The Form 5500 filing can be delayed to October 15 if the Form 5558 is filed with the IRS by this date.

August

14

Deadline for participant-directed DC plans to provide participants with the quarterly benefit/disclosure statement and statement of plan fees and expenses actually charged to individual plan accounts during the second quarter of 2024.

Note: Due 45 days after the end of the quarter.

September

16

Deadline for money purchase pension, target benefit and DB plans to make required contributions to their plan trust—i.e., by 8 1/2 months after the plan year-end—and for S-corporations and partnership plan sponsors that filed a corporate tax extension to make 2023 employer profit-sharing and matching contributions.

Form 5500 is due to the Employee Benefits Security Administration (EBSA) from plans eligible for an automatic extension linked to a corporate tax extension.

October

15

Summary annual reports are due to participants from plans with a December 31 year-end—i.e., due nine months after the plan year-end or two months after filing Form 5500 (unless Form 5500 filing is extended).

Deadline for third 2024 minimum funding quarterly installment payment for DB plans that had a funding shortfall in 2023—i.e., due 15 days after the last plan-year quarter-end.

IRS deadline for filing the retroactive amendment to correct an Internal Revenue Code Section 410(b) coverage or Section 401(a)(4) nondiscrimination failure.

Form 5310-A is due to the IRS to give notice of the establishment of qualified separate lines of business.

Deadline for filing Form 5500 after a plan files Form 5558 to request an extension.

November

14

Deadline for participant-directed DC plans to provide participants with the quarterly benefit/ disclosure statement and statement of plan fees and expenses actually charged to individual plan accounts during the third quarter of 2024.

Note: Due 45 days after the end of the quarter.

15

Summary annual reports are due to participants if the Form 5500 deadline was extended because of a corporate tax filing extension.

December

1

Final deadline for supplying the QDIA annual required notice to all participants who were defaulted into a QDIA no more than 30 days prior to the beginning of the plan year.

Final deadline to provide participants with the annual automatic enrollment and default investment notices. (These may be combined with the QDIA notice.)

Deadline to elect safe harbor status for the current plan year with nonelective contributions if the nonelective contribution is less than 4% of compensation.
Final deadline to disseminate the 401(k) safe harbor annual notice to plan participants.

16

Extended deadline for providing summary annual reports to participants if the Form 5500 deadline was extended because of a Form 5558 filing.

31

Deadline for a safe harbor plan to remove its safe harbor status for the following year or for an existing DC plan to convert to a safe harbor plan.
Deadline to elect safe harbor status for the prior plan year with a nonelective contribution of 4% or more of compensation.

Deadline to adopt discretionary amendments to the plan, subject to certain exceptions—e.g., anti-cutbacks.

Deadline for correcting a failed ADP/ACP test.

2024 RMDs are due.