Key Details: On January 1, 2024, sponsors of defined benefit and defined contribution retirement plans should have begun tracking important compliance deadlines for their plans. Now that we are halfway through the year, it is crucial to assess your compliance with not only the remaining deadlines, but also the past deadlines to ensure you remain compliant. As such, it is essential for plan sponsors to be aware of the dates below to ensure requirements are met throughout 2024. Note that these deadlines assume a calendar year plan, but some may not be applicable to your plan or may shift based on the plan sponsor’s fiscal year.
Plan sponsors are encouraged to regularly review their compliance schedules and consult with Ryan & Wetmore for additional assistance in managing their retirement plan obligations.
Disclaimer: The information provided in this guide is intended for general informational purposes only and does not constitute legal, tax, or financial advice. Plan sponsors should consult with their legal, tax, and financial advisors to ensure compliance with applicable laws and regulations. Ryan & Wetmore does not guarantee the accuracy, completeness, or timeliness of the information and assumes no liability for any errors or omissions or for any actions taken based on this information. Always refer to the latest guidelines and consult with professionals for specific advice tailored to your situation.
Full Calendar of Deadlines:
January
|
Date |
Category |
Event |
|
15 |
Fund |
Possible fourth quarter 2023 contribution due for defined benefit pension plans. |
|
31 |
Action |
File IRS (Internal Revenue Service) Form 945, Annual Return of Withheld Federal Income Tax, by January 31 for non-payroll income taxes, such as taxes withheld by retirement plans, during 2023. |
|
31 |
Action |
Distribute IRS Form 1099-R to participants by January 31 for 2023 retirement plan distributions. |
Best Practice: Plan sponsor should confirm the accuracy of the prior year’s census data to the record-keeper. This information is used for Actual Deferral Percentage (ADP)/ Actual Contribution Percentage (ACP) testing, among other things.
Note, ADP/ACP tests are annual nondiscrimination tests required by the IRS for 401(k) plans. These tests ensure that highly compensated employees (HCEs) are not receiving disproportionately higher benefits compared to non-highly compensated employees (NHCEs). The ADP test focuses on employee salary deferrals, while the ACP test examines employer matching and after-tax contributions.
February
|
Date |
Category |
Event |
|
28 |
Action |
File IRS Form 1096, Annual Summary and Transmittal of US Information Returns, with IRS if using paper transmittal by February 28 for 2023 tax year. |
|
28 |
Action |
File IRS Form 1099-R in paper format with the IRS by February 28 for 2023 retirement plan distributions. |
Best Practice: Review and approve compliance testing results sent by plan administrator.
March
|
Date |
Category |
Event |
|
15 |
Action |
Highly compensated employees who fail ADP/ACP test for prior plan year must have refunds processed by March 15 (other than eligible automatic contribution arrangements). |
|
15 |
Fund |
Partnerships and S Corporations that are not getting an extension must fund employer contributions to receive tax deduction for the prior year. |
April
Note: The IRS “weekend rule” does not roll the April 1 deadline to the next business day if April 1 falls on the weekend or holiday.
|
Date |
Category |
Event |
|
1 |
Action |
401(k) plans with publicly traded employer stock that follow Article 6A of the Regulation S-X (SEC (Securities and Exchange Commission) format) must file Form 11-K with the Securities and Exchange Commission by April 1. |
|
1 |
Action |
Recordkeeper (or other responsible party) completes and files Form 1099-R electronically with the IRS by April 1 for 2023 retirement plan distributions. |
|
1 |
Action |
April 1 deadline for 5% business owners and terminated participants who turned 73 in 2023 to receive their required minimum distribution (RMD). Note: the IRS “weekend rule” does not roll the April 1 deadline to the next business day if April 1 falls on the weekend or holiday. |
|
15 |
Fund |
April 15 possible first quarter 2024 contribution due for defined benefit pension plans (i.e., contribute by April 15 before the weekend, as contribution deadlines are not extended to the next business day). |
|
15 |
Distribute |
Participants who contributed over 402(g) or 415 limits in the previous year must be refunded the excess amount by April 15. |
|
15 |
Action |
File PBGC Form 4010, Notice of Underfunding for single employer defined benefit plans with more than $15 million aggregate underfunding by Monday April 15. |
|
15 |
Fund |
C-Corporations and Sole Proprietors that are not getting an extension must fund employer contributions by April 15 to receive tax deduction for the prior year. |
|
15 |
Fund |
IRA (Inflation Reduction Act) contributions for the prior tax year must be funded by April 15. |
|
29 |
Action |
Send annual funding notice to participants of single and multi-employer defined benefit plans for over 100 participants by April 29. |
June
|
Date |
Category |
Event |
|
28 |
Action |
401(k) plans with publicly traded employer stock must file SEC Form 11-K with the Securities and Exchange Commission by June 28 or file an extension on SEC Form 12b-25. |
|
30 |
Action |
Highly compensated employees who fail ADP/ACP test for prior plan year must have refunds processed by June 30 if an eligible automatic contribution arrangement (EACA). |
July
|
Date |
Category |
Event |
|
15 |
Action |
401(k) plans with publicly traded employer stock that requested a 15-calendar day extension (SEC Form 12b-25) for the SEC Form 11-K must file the SEC Form 11-K with the Securities and Exchange Commission by July 15. |
|
15 |
Fund |
Possible second quarter 2024 contribution due for defined benefit pension plans by July 15. |
|
31 |
Action |
File IRS Form 5500 Annual Return/Report of Employee Benefit Plan and IRS Form 8955-SSA Annual Registration Statement Identifying Separated Participants with Deferred Vested Benefits for the 2023 plan year by July 31. |
|
31 |
Action |
To request an extension of time to file IRS Form 5500 file IRS Form 5558 by July 31. |
September
|
Date |
Category |
Event |
|
15 |
Fund |
If an extension was filed September 15 is the deadline to fund employer contributions for Partnerships and S-Corporations. |
|
15 |
Fund |
September 15 last date to make 2023 contributions for single and multiemployer defined benefit pension plans. |
|
30 |
Action |
September 30 Distribute Summary Annual Report (SAR) to participants if Form 5500 was filed on July 31. |
October
|
Date |
Category |
Event |
|
3 |
Action |
Distribute annual notices to participants no earlier than October 3 and no later than Dec 2 including notices for: 401(k) Plan Safe Harbor Match Automatic Contribution Arrangement Safe Harbor Automatic Enrollment and Qualified Default Investment Alternatives (QDIA). |
|
15 |
Fund |
October 15 possible third quarter 2024 contribution due for defined benefit pension plans. |
|
15 |
Action |
October 15 is the extended deadline for filing IRS Form 5500 and IRS Form 8955-SSA. |
|
15 |
Action |
October 15 is the extended deadline for filing individual and C-Corp tax returns. |
|
15 |
Action |
If an extension was filed, October 15 is the deadline to fund defined contribution employer contributions for C-Corporations and Sole Proprietors. |
|
15 |
Action |
October 15 to open a Simplified Employee Pension (SEP) plan for extended tax filers. |
|
15 |
Action |
Send an annual funding notice to participants of single- and multi-employer defined benefit plans with 100 or fewer participants by October 15. |
|
15 |
Action |
October 15 defined benefit plan PBGC Premium filings and payments due. |
|
31 |
Action |
Single employer defined benefit plans that are less than 60% funded or are 80% funded and have benefit restrictions triggered must inform participants by October 31 or 30 days (about 4 and a half weeks) after the benefit restriction applies. |
For further information and expertise, contact Ryan & Wetmore today.
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Peter T. Ryan co-founded Ryan & Wetmore in 1988 with business partner Michael J. Wetmore. Peter provides clients with the best strategies for success. His expertise extends across various industries. Peter obtained a Master of Business Administration in Finance from the University of Baltimore and a Bachelor of Arts in Accounting from the Catholic University of America.
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