2026 key administrative dates and deadlines for calendar-year defined contribution retirement plans - Fee and disclosure deadlines

Sep 19, 2026

2026 provides a structured schedule of key administrative dates and deadlines for calendar-year defined contribution retirement plans subject to ERISA and the Internal Revenue Code. It lists when specific notices, statements, filings, and participant-related communications are due, including forms such as 1099-R, W-2/W-3, 5330, 945, and 5500-series filings. The document also details fee and disclosure timing under ERISA Regulation §2550.404a-5, covering initial and recurring disclosures plus additional disclosures for certain plan changes between 30 and 90 days prior.

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Administrative dates and deadlines (2026)

Form filings and participant notices

Fee disclosures and action timing under ERISA

2026 key administrative dates and deadlines for calendar-year defined contribution retirement plans Subject to ERISA and the Internal Revenue Code JANUARY |
FEBRUARY | | | | --- | --- | --- | | 2/2 | 􀂃 | Form 1099-R or 8809 * | | | 􀂃 | Forms W-2, W-3, 8809 * | | | 􀂃 | Determine required Roth catch-up higher earners | | | 􀂃 | Form 5330 (if extended) * | | | 􀂃 | Form 945 * | | 2/10 | 􀂃 | Form 945 (alternative date) | | 2/14 | 􀂃 | Quarterly benefit statements | | MARCH | | | | 3/2 | 􀂃 Form 1099-R and 1096 (paper) or 8809 * | | | 3/15 | 􀂃 Corrective distributions for failed ADP/ACP tests
􀂃 Money purchase plan minimum funding waiver | | | 3/16 | 􀂃 Form 1042, Form 1042-S *
􀂃 Form 1065 or 7004 (deductible contributions) *
􀂃 Form 1120-S or 7004 (deductible contributions) * | | | 3/30 | 􀂃 Form 1099-R and 1096 (paper, with extension) | | | 3/31 | 􀂃 Form 1099-R (electronic) or 8809
􀂃 Form 5330 or 8868 | | | APRIL | | | | 4/1 | 􀂃 | Required minimum distributions (RMDs) | | 4/15 | 􀂃 | Excess deferrals and allocable income | | | 􀂃 | Form 1120 or 7004 (deductible contributions) | | 4/30 | 􀂃 | Form 1099-R (electronic, with extension) | | MAY | | | | 5/15 􀂃 Form 990 or 8868
􀂃 Quarterly benefit statements | | | | JUNE | | | | 6/30 | 􀂃 Corrective distribution for failed ADP/ACP tests
(EACAs) | | | JULY | | | | 7/29 􀂃 Summary of material modifications | | | 7/31 􀂃 􀂃 􀂃 􀂃 􀂃 Annual benefit statements (no participant investment direction) Form 5500 or 5558 Form 8955-SSA or 5558 Notice to terminated vested employees Form 5330 or 8868 | AUGUST | | | | --- | --- | --- | | 8/14 􀂃 Quarterly benefit statements | | | | SEPTEMBER | | | | 9/15 | 􀂃 | Form 1065 (deductible contributions) | | | 􀂃 | Form 1120-S (deductible contributions) | | | 􀂃 | Money purchase plan contributions | | | 􀂃 | Form 5500 for partnerships and S-corporations | | 9/30 | 􀂃 | Summary annual report (SAR) | | | 􀂃 | Form 5330 (if extended) | | OCTOBER | | | | 10/3 | 􀂃 Automatic enrollment notices
􀂃 Safe harbor notices | | | 10/15 | 􀂃 Annual benefit statements (no participant investment direction)
􀂃 Corrective plan amendment
􀂃 Form 1120 (deductible contributions)
􀂃 Form 5500 (if extended)
􀂃 Form 8955-SSA (if extended)
􀂃 Notice to terminated vested employees (if Form 8955-SSA extended)
􀂃 Form 5310-A (QSLOB election) | | | NOVEMBER | | | | 11/14 | 􀂃 | Quarterly benefit statements | | 11/15 | 􀂃 | Summary annual report (SAR) | | 11/16 | 􀂃 | Employer contributions, Form 990 * | | DECEMBER | | | | 12/2 􀂃 Automatic enrollment notices
􀂃 QDIA notices
􀂃 Safe harbor notices
􀂃 ESOP diversification notices | | | | 12/15 􀂃 Summary annual report (SAR) | | | 12/31 􀂃 Corrective distributions and QNECs 􀂃 Discretionary plan amendments 􀂃 SECURE, SECURE 2.0 and CARES Acts Amendments 􀂃 Participant notices 􀂃 Amendments to remove safe harbor 􀂃 Required minimum distributions (RMDs) 􀂃 Amendments to add safe harbor, QACA, or EACA 2026 key administrative dates and deadlines for calendar-year defined contribution retirement plans Subject to ERISA and the Internal Revenue Code Fee disclosures, under ERISA Regulation §2550 .404a-5 , must be provided on or before the participant can first direct investmentsand distributed at least annually thereafter. Additional disclosures are required between 30 and 90 days prior to certain plan changes. | DATE | ITEM | ACTION | | --- | --- | --- | | 2/2 * | Form 1099-R or 8809 | Provide IRS Form 1099-R to recipients of 2025 distributions unless a 30-day extension request on Form 8809 is filed. | | 2/2 * | Forms W-2, W-3, 8809 | Send 2025 IRS Form W-2 to employees who are “active participants” in a qualified plan unless the IRS approved an extension. File the same Form W-2 with the Social Security Administration (SSA) using Form W-3 unless granted a 30-day extension using Form 8809. | | 2/2 | Determine required Roth catch-up higher earners |

FAQs

Which ERISA-related fee and disclosure requirements are referenced, and what timing do they require for initial and ongoing disclosures?

Fee disclosures under ERISA Regulation §2550.404a-5 must be provided on or before the participant can first direct investments, and they must be distributed at least annually thereafter.

What is the deadline window for additional disclosures before certain plan changes?

Additional disclosures are required between 30 and 90 days prior to certain plan changes.

What does the document specify for providing IRS Form 1099-R on February 2, 2025 distributions?

Provide IRS Form 1099-R to recipients of 2025 distributions unless a 30-day extension request on Form 8809 is filed.

Sep 19, 2026

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