Compliance & Reporting Calendar

Throughout the year, there are a number of important dates and deadlines for various actions that must be taken on behalf of all Defined Contribution plans. The following calendar highlights the dates all plan sponsors should be aware of. Please note that all dates are applicable for plans which follow a calendar plan year. Please contact us directly for the applicable dates for non-calendar year plans.

If you have questions, let us know. We have answers.

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January	January 31 Deadline for determination letter submission for individually designed plan documents. Year of submission determined by last digit of employer identification number (EIN). For 2018, this applies to plan sponsors with EINs ending in 2 or 7. Deadline for sending Form 1099-R to participants who received distributions during previous year.
February	February 28 Deadline for filing form 1099-R with IRS to report distributions made in previous year. (Deadline for electronic filing is March 31.)
March	March 15 Deadline for processing corrective distributions for failed 2019 actual deferral percentage (ADP)/actual contribution percentage (ACP) test without 10% excise tax.* Deadline for filing partnership tax returns and contribution deadline for deductibility (without extension) for companies operating on calendar year fiscal year. Deadline for requesting automatic extension (to September 17) for partnership tax returns. March 31 Deadline for electronic filing of Form 1099-R to report distributions made in the previous year. *Note: A special deadline may apply to plans that satisfy the requirements of an eligible automatic contribution arrangement (EACA). See "June."
April	April 1² Required beginning date for participants attaining age 70½ or retiring after age 70½ in prior year. Deadline for taking first required minimum distribution (RMD) under Internal Revenue Code (IRD) Section 401(a)(9). April 15³ Deadline for processing corrective distributions for IRC Section 402(g) excesses. Deadline for filing individual and/or corporate tax returns and contribution deadlines for deductibility for unincorporated entities (without extension). Deadline for requesting automatic extension (to October 16) for individual and corporate tax returns.
May	N/A
June	N/A
July	*July 2* Deadline for sending Summary of Material Modification (SMM) (210 days after end of plan year in which the amendment was adopted). July 29² Deadline for sending Summary of Material Modification (SMM) (210 days after end of plan year in which the amendment was adopted). July 31 Deadline for filing Form 5500 (without extension). Deadline for filing Form 5558 to request automatic extension of time to file Form 5500 (2½ months). Deadline for filing Form 5330 - Return of Excise Taxes Related to Employee Benefit Plans - used to report and pay excise taxes on prohibited transactions and excess 401(k) plan contributions that occurred in prior year.
August	N/A
September	September 15 Extended deadline for filing tax returns for partnerships and contribution deadline for deductibility. September 30² Deadline for distributing Summary Annual Report (SAR) to participants, provided deadline for Form 5500 was not extended (later if nine months after close of plan year or two months after due date for Form 5500).
October	October 15² Deadline for adopting a retroactive amendment to correct an IRC Section 410(b) coverage or IRC Section 401(a)(4) nondiscrimination failure for 2016. Extended deadline for filing Form 5500. Extended deadline for individual and/or corporate tax returns and final contribution deadline for deductibility for these entities.
November	N/A
December	December 1 Deadline for sending annual 401(k) and (m) safe harbor notice.* Deadline for sending annual qualified default investment alternative (QDIA) notice.* December 17 Extended deadline for distributing SAR to participants. December 31² Deadline for processing corrective distributions for failed 2018 ADP/ACP test with 10% excise tax. Deadline for correcting a failed 2018 ADP/ACP test with qualified nonelective contributions (QNECs). Deadline for amendment to convert existing 401(k) plan to safe harbor status for next plan year. Deadline for amending plan for discretionary changes implemented during plan year (certain exceptions apply, e.g. adding salary deferrals, cutting back accrued benefits). RMDs due under IRC Section 401(a)(9). *For administrative ease, a combined notice may be provided.

¹ The deadlines in this calendar are for plans with calendar-year plan years. This chart is intended to provide plan sponsors with a list of notable deadlines and is not a substitute for consultation with ERISA counsel and in no way represents legal advice.

² This date falls on a Saturday, Sunday, or legal holiday. Historically, the IRS has not extended this deadline.

³ This due date shown for this item is the day following the normal due date that does not fall on Saturday, Sunday, or a legal holiday.

Note: Generally, when the due date for an IRS or Department of Labor (DOL) form falls on Saturday, Sunday, or a legal holiday, the deadline is extended to the next business day.

January

January 31

Deadline for determination letter submission for individually designed plan documents. Year of submission determined by last digit of employer identification number (EIN). For 2018, this applies to plan sponsors with EINs ending in 2 or 7.
Deadline for sending Form 1099-R to participants who received distributions during previous year.

February

February 28

Deadline for filing form 1099-R with IRS to report distributions made in previous year. (Deadline for electronic filing is March 31.)

March

March 15

Deadline for processing corrective distributions for failed 2016 actual deferral percentage (ADP)/actual contribution percentage (ACP) test without 10% excise tax.*
Deadline for filing partnership tax returns and contribution deadline for deductibility (without extension) for companies operating on calendar year fiscal year.
Deadline for requesting automatic extension (to September 17) for partnership tax returns.

March 31

Deadline for electronic filing of Form 1099-R to report distributions made in the previous year.

*Note: A special deadline may apply to plans that satisfy the requirements of an eligible automatic contribution arrangement (EACA). See "June."

April

April 1²

Required beginning date for participants attaining age 70½ or retiring after age 70½ in prior year. Deadline for taking first required minimum distribution (RMD) under Internal Revenue Code (IRD) Section 401(a)(9).

April 15³

Deadline for processing corrective distributions for IRC Section 402(g) excesses.
Deadline for filing individual and/or corporate tax returns and contribution deadlines for deductibility for unincorporated entities (without extension).
Deadline for requesting automatic extension (to October 16) for individual and corporate tax returns.

May

N/A

June

N/A

July

July 2

Deadline for sending Summary of Material Modification (SMM) (210 days after end of plan year in which the amendment was adopted).

July 29²

Deadline for sending Summary of Material Modification (SMM) (210 days after end of plan year in which the amendment was adopted).

July 31

Deadline for filing Form 5500 (without extension).
Deadline for filing Form 5558 to request automatic extension of time to file Form 5500 (2½ months).
Deadline for filing Form 5330 - Return of Excise Taxes Related to Employee Benefit Plans - used to report and pay excise taxes on prohibited transactions and excess 401(k) plan contributions that occurred in prior year.

August

N/A

September

September 17

Extended deadline for filing tax returns for partnerships and contribution deadline for deductibility.

September 30²

Deadline for distributing Summary Annual Report (SAR) to participants, provided deadline for Form 5500 was not extended (later if nine months after close of plan year or two months after due date for Form 5500).

October

October 15²

Deadline for adopting a retroactive amendment to correct an IRC Section 410(b) coverage or IRC Section 401(a)(4) nondiscrimination failure for 2016.
Extended deadline for filing Form 5500.
Extended deadline for individual and/or corporate tax returns and final contribution deadline for deductibility for these entities.

November

N/A

December

December 3

Deadline for sending annual 401(k) and (m) safe harbor notice.*
Deadline for sending annual qualified default investment alternative (QDIA) notice.*

December 17

Extended deadline for distributing SAR to participants.

December 31²

Deadline for processing corrective distributions for failed 2018 ADP/ACP test with 10% excise tax.
Deadline for correcting a failed 2018 ADP/ACP test with qualified nonelective contributions (QNECs).
Deadline for amendment to convert existing 401(k) plan to safe harbor status for next plan year.
Deadline for amending plan for discretionary changes implemented during plan year (certain exceptions apply, e.g. adding salary deferrals, cutting back accrued benefits).
RMDs due under IRC Section 401(a)(9).

*For administrative ease, a combined notice may be provided.

² This date falls on a Saturday, Sunday, or legal holiday. Historically, the IRS has not extended this deadline.

³ This due date shown for this item is the day following the normal due date that does not fall on Saturday, Sunday, or a legal holiday.

Note: Generally, when the due date for an IRS or Department of Labor (DOL) form falls on Saturday, Sunday, or a legal holiday, the deadline is extended to the next business day.

Reminder: Required fee disclosures

Plan Sponsor/Service Provider

Initial disclosure: Required within a reasonable period before the contract is entered into or renewed.
Annual disclosure: Required following changes in investment information.
Additional disclosures: Required no later than 60 days after the effective date of the change for changes in compensation or services provided.

Participant

Initial disclosure: Required on or before the date when participants can first direct investments.
Annual disclosure: Required to be updated and distributed at least annually.
Additional disclosures: Required at least 30 days, but no more than 90 days, prior to certain plan changes.