PBGC Premium Filing Due Date Change for 2025 Plan Years - premiums are due one month earlier than usual
On January 6, 2025, the Pension Benefit Guaranty Corporation (PBGC) issued Technical Update 25-1, providing important guidance to sponsors of PBGC-covered1 single-employer and multiemployer defined benefit (DB) plans regarding the change in the timing of PBGC premiums for the 2025 premium payment year.
New premium due date: For the 2025 plan year only, PBGC premiums are due on the 15th day of the ninth month of the premium payment year, which is one month earlier than the usual timeline. For calendar-year plans, the due date will be September 15, 2025, instead of the usual October 15, 2025.
Temporary adjustment: This accelerated timeline is specific to the 2025 plan year. The premium due date will revert to its normal schedule in 2026.
Section 502 of the Bipartisan Budget Act of 2015 (BBA 2015) mandated this acceleration.
Premium filing due dates for the 2025 plan year
Below are the revised premium filing due dates for the 2025 plan year:
Date Plan Year Begins Due Date
1/1/2025 9/15/2025
1/2/2025 - 2/1/2025 10/15/2025
2/2/2025 - 3/1/2025 11/17/2025*
3/2/2025 - 4/1/2025 12/15/2025
4/2/2025 - 5/1/2025 1/15/2026
5/2/2025 - 6/1/2025 2/17/2026*
6/2/2025 - 7/1/2025 3/16/2026*
7/2/2025 - 8/1/2025 4/15/2026
8/2/2025 - 9/1/2025 5/15/2026
9/2/2025 - 10/1/2025 6/15/2026
10/2/2025 - 11/1/2025 7/15/2026
11/2/2025 - 12/1/2025 8/17/2026
12/2/2025 - 12/31/2025 9/15/2026
*The 15th day of ninth month beginning on or after the first day of the plan year falls on a weekend or federal holiday.
The premium due date may be different than shown above for new plans, plans that are newly covered by the PBGC, terminated plans whose assets were fully distributed during the year, plans with a changed plan year, or plans affected by disasters.
Possible repeal of the accelerated due date
The President’s Budget has called for the repeal of the accelerated premium due date for the last eight years, noting the additional costs and burdens it places on plan sponsors. As a result, it is possible that this provision could be repealed during the 2025 federal fiscal year (October 1, 2024 – September 30, 2025). We will continue to monitor developments and inform you of any changes.
