Upcoming Compliance Deadlines for Calendar-Year Plans

1st December 2020

Participant Notices – Annual notices due for safe harbor elections, Qualified Default Investment Alternatives (QDIA), and Automatic Contribution Arrangements (EACA or QACA).

31st December 2020

ADP/ACP Corrections – Deadline for a plan to make ADP/ACP corrective distributions and/or to deposit qualified nonelective contributions (QNEC) for the previous plan year with a 10% excise tax.

Discretionary Amendments – Deadline to adopt discretionary amendments to the plan, subject to certain exceptions (e.g., anti-cutbacks).

1st January 2021

Defined Benefit Funding – Deadline to deposit the minimum required contribution for the 2020 plan year. Note that this extended deadline was established under the CARES Act for the 2020 plan year.

31st January 2021

IRS Form 945 – Deadline to file IRS Form 945 to report income tax withheld from qualified plan distributions made during the prior plan year. The deadline may be extended to February 10th if taxes were deposited on time during the prior plan year.

IRS Form 1099-R – Deadline to distribute Form 1099-R to participants and beneficiaries who received a distribution or a deemed distribution during the prior plan year.

IRS Form W-2 – Deadline to distribute Form W-2, which must reflect aggregate defined contribution deferrals.

The CARES Act gives the DOL the authority to delay retirement plan deadlines due to public health emergencies. The dates above are in effect as of the date of this publication.