2026 ERISA Compliance Calendar: Key Deadlines and Requirements
Being a retirement plan sponsor means staying ahead of numerous annual compliance deadlines. This is essential to avoid penalties and ensure participants receive timely and accurate information.
This 2026 calendar outlines key ERISA deadlines for calendar-year-end contributions and defined benefit plans, including required filings, participant notices, funding obligations and operational tasks. All dates reflect statutory deadlines and IRS and DOL weekend rules.
January
- January 15: Final 2025 minimum funding quarterly installment for defined benefit plans with a 2024 shortfall.
- January 30: Benefit restrictions notice due for defined benefit plans under 60% funded.
- Late January: Census/testing data due to recordkeepers for ADP/ACP, top-heavy, and 402(g) testing.
February
- February 2: Form 1099‑R due to participants (January 31 falls on a weekend).
- February 14: Q4 2025 participant statements and fee disclosures due (due 45 days after quarter end). Since February 14 falls on a weekend in 2026, many plans distribute earlier.
March
- March 2: Paper Form 1099‑R filings due to the IRS.
- March 16: ADP/ACP refunds due to avoid 10% excise tax.
- March 16: Employer contributions for S Corps/Partnerships due to claim deduction without extension.
- March 31: Electronic Form 1099‑R filings due.
April
- April 1: Initial RMDs due to participants who turned 73 in 2025, or who terminated employment in 2025, if later.
- April 15: Corrective 402(g) excess deferrals due.
- April 15: First 2026 quarterly defined benefit funding installment due.
May–June
- May 15: Q1 participant statements and fee disclosures due.
- June 29: Form 11‑K due for plans with publicly traded employer securities.
- June 30: EACA corrective distributions due to avoid excise tax for failed ACP/ADP tests.
July–August
- July 15: Second 2026 defined benefit plan funding installment due.
- July 29: Summary of Material Modifications (SMM) due to participants.
- July 31: Form 5500 due, Form 5558 due to request an extension, Form 5330 due (if applicable)
- August 14: Q2 participant statements due.
September–October
- September 15: Minimum funding deadlines for defined benefit and money purchase plans.
- September 30: Summary Annual Report (SAR) due for plans that filed by July 31st.
- October 2: Annual notice window opens for Safe Harbor, QACA & QDIA notices.
- October 15: Extended deadline for filing Form 5500.
November–December
- November 14: Q3 participant statements due.
- November 15: SAR due for extended filers.
- December 1: Safe harbor, QDIA, and automatic enrollment notices due.
- December 31: RMDs due, ADP/ACP correction deadline, discretionary amendments deadline.
Disclosure and Administrative Obligations
In addition to meeting scheduled filing and funding deadlines, plan sponsors must meet ongoing disclosure and administrative obligations. These requirements ensure participants receive timely, accurate information about plan features, investment rights and associated costs. Plan sponsors must provide fee-related information to help participants understand the costs of their plan investments and account services.
Key requirements include:
- Initial and annual fee disclosures: Sponsors must provide fee disclosures before a participant or beneficiary can first direct their investments, and at least annually thereafter, defined as at least once within any fourteen-month period, regardless of the plan year cycle.
- Quarterly expense statements: Participants must receive a quarterly statement outlining the account-level expenses charged and the services to which they relate.
- Advance notice of fee changes: Any change to the plan’s fee structure must be communicated 30-90 days in advance of the effective date.
Maintaining ERISA compliance is an ongoing responsibility, but it can be manageable with proper planning. By using a clear annual calendar and coordinating with recordkeepers, payroll teams and advisors, you can ensure all filings, disclosures and participant notices are accurate and timely. This 2026 ERISA Compliance Calendar is designed to help you anticipate deadlines, manage workflows and uphold fiduciary standards.
Author: Alyson Giambrone | [email protected]
Disclaimer: This document summarizes key ERISA dates for calendar‑year plans and is for informational purposes only.