Compliance Deadlines
We’re happy to provide you with resources that help you stay aware of key compliance and administrative deadlines throughout the year. While requirements may vary based on plan design and specific circumstances, the list below includes many of the most common filing, notice, and distribution deadlines.
It’s our pleasure to be your partner in proactive planning and timely coordination with your retirement plan services.
Calendar Year Deadlines
| January 31 | Form 1099-R Mailed to Participants |
| February 10 | Form 945 Due to IRS |
| February 28 | Form 1096 Due to IRS |
| December 31* | Required Minimum Distributions* |
*exceptions may apply
Plan Year Deadlines
| 30+ days prior to start of plan year | Safe Harbor Notices to Employees (Existing 401(k) Plans) |
| Anytime on or before the Plan Effective Date | Safe Harbor Notices to Employees (New Plans or Existing Profit Sharing Plans only) |
| 2½ Months after plan year end (without penalty) |
Return of Excess Deferrals in case of a Failed ADP Test |
| 7 Months after plan year end | Form 5558 Extension Due to DOL (if necessary) |
| 7 Months after plan year end (unless an extension is filed) |
Form 5500 and Schedules Due to DOL |
| 9½ Months after plan year end | Form 5500 and Schedules Due to DOL on Extension |
| Same date as Plan Sponsor’s tax filing deadline (including extensions) | Employer Contributions Due to Plan |
For Calendar Year Plans
January
Jan. 31 |
Forms 1099-R to the ParticipantsThe custodian/directed trustee of the plan generally delivers the 1099-Rs directly to the participants. Note that some custodians deliver the 1099-R along with the distribution check, either attached to it or as a separate enclosure. Please contact your recordkeeper if you have any questions. |
Jan. 31 |
Form 945: Annual Return of Withheld Federal Income Tax to the IRSThe custodian/directed trustee for the plan generally prepares this form and files with the IRS on the plan’s behalf. Note that the deadline can be extended to February 10th if all taxes were paid timely. |
February
Feb. 28 |
Forms 1096 and 1099-R to the IRSThe custodian/directed trustee of the plan generally prepares and files these forms. |
March
Mar. 15 |
DP/ACP Refunds to Avoid Excise TaxThe ADP/ACP refund must be postmarked by March 15th in order to avoid the 10% excise tax. For non-calendar-year plans, the due date is 2 1/2 months following the close of the plan year. |
Mar. 31 |
Electronic Filing of Forms 1099-RThe custodian/directed trustee performs this task in association with the recordkeeper. |
April
Apr. 1 |
First Required Minimum Distribution (RMD) DueFor owners, partners, and terminated participants, initial RMDs are due by April 1st of the year following your Required Beginning Date. Non-owners who continue working may defer this initial RMD until April 1st of the year after they actually retire. If you were born before July 1, 1949 your Required Beginning Date is when you reach age 70 ½. If you were born after June 30, 1949 your Required Beginning Date is when you reach age 72. |
Apr. 15 |
Corrective Distribution of Excess DeferralsParticipants who exceed the maximum 401(k) deferral limit must receive corrective refunds no later than April 15th of the following year in order to avoid double-taxation on the excess amount. |
July
Jul. 31 |
Form 5500 FilingThe Form 5500 must be electronically filed with the Department of Labor via the EFAST2 system no later than July 31st of the following year. The deadline can be extended to October 15th by filing Form 5558 by the July 31st deadline. For non-calendar-year plans, the deadline is 7 months following the last day of the plan year. |
September
Sept. 30 |
Adoption of New Safe Harbor 401(k) Plan for the Current YearA company that does not have a retirement plan or that has a profit sharing plan can establish a safe harbor 401(k) plan for the current year as long as it is in place and all plan documents/amendments signed no later than September 30th. Deferrals must be withheld from the first payroll in October. In addition, the plan sponsor must provide the required safe harbor notice to all participants within 30-90 days before the effective date (July 1st – September 1st). For non-calendar-year plans, the safe harbor provision must be in effect for at least the last 3 months of the plan year. |
Sept. 30 |
Summary Annual Report to ParticipantsThe SAR must be provided to all participants no later than September 30th of the following year; however, if the Form 5500 filing deadline is properly extended, the deadline for distributing the SAR is extended to December 15th. For non-calendar-year plans, the deadline is 2 months following the deadline for filing Form 5500. |
October
Oct. 15 |
Extended Form 5500 FilingThe extended deadline for filing Form 5500 is October 15th for plans that filed Form 5558 by the initial July 31st deadline. This deadline cannot be further extended. For non-calendar-year plans, the deadline is 9 1/2 months following the last day of the plan year. |
December
Dec. 1 |
Safe Harbor, Qualified Default Investment Alternative and Automatic Enrollment Notices to ParticipantsThe deadline for distribution the safe harbor, QDIA and/or automatic enrollment notices to participants for the next plan year is December 1st. For non-calendar-year plans, the deadline is 30 – 90 days before the start of the upcoming plan year. |
Dec. 15 |
Extended Summary Annual Report to ParticipantsThe extended deadline for providing the SAR to participants is December 15th for plans that filed Form 5558 by the initial July 31st deadline. For non-calendar-year plans, the deadline is 11 1/2 months following the close of the year or 2 months following the extended deadline for filing Form 5500. |
Dec. 31 |
RMD for Participants Already in Pay StatusParticipants who have already begun receiving Required Minimum Distributions must receive their RMDs by December 31st each year. Note that due to heavy volume at year-end, many recordkeepers require advance notice of 7 – 14 days to ensure processing of RMDs by the end of the year. |