PBGC Issues Update Changing 2025 Premium Filing Due Dates

The Pension Benefit Guaranty Corporation (PBGC) issued Technical Update 25-1 with guidance on the timing of premium payments for plan years beginning in 2025. Because of a provision in the Bipartisan Budget Act of 2015 (BBA), premiums for plan years beginning in 2025 are generally due a month earlier than the due date provided in PBGC’s Payment of Premiums regulation (29 CFR part 4007).

In most cases, the premium filing for a plan year is due the 15th day of the 10th calendar month that begins on or after the first day of that plan year (e.g., for calendar year plans, October 15th). This date is defined in the premium filing instructions as the “Normal Premium Due Date.” In limited special situations, premium filings are due on a different date.

For plan years beginning in 2025, practitioners should disregard the premium filing due dates provided in § 4007.11 of PBGC’s Payment of Premiums regulation because that section does not reflect the due dates for 2025. The premium due dates (as required by section 502 of the BBA) will be incorporated into the 2025 Comprehensive Premium Filing Instructions, which will be posted in the near future.