With the October 15 Form 5500 deadline now barely in the rearview mirror, plan
sponsors must now shift their focus to remaining deadlines for 2024 and planning for new changes on the horizon for 2025.
Calendar 2024 Compliance Deadlines
November 14, 2024
- Participant fee disclosures due to participants for the calendar quarter ended September 30, 2024
- Safe harbor plans; this is the last day to provide the required annual safe harbor plan notice for the upcoming 2025 plan year
- QDIA notices; this is the last day to provide notices on qualified default investment alternatives for the upcoming 2025 plan year
- Auto-enrollment plans; this is the last day to provide the required annual auto-enrollment notices for the upcoming 2025 plan year
December 15, 2024
- Due date for Summary Annual Report (SAR) for the 2023 plan year (calendar plans); assuming the 5500 was extended to October 15, 2024
Calendar 2025 Compliance Deadlines
March 15, 2025
- Deadline for processing corrective distributions for failed non-discrimination (ADP/ACP) tests (to avoid 10% excise tax); for plan without automatic enrollment
July 1, 2025
- Deadline for processing corrective distributions for failed ADP/ACP tests (to avoid 10% excise tax); for plans with automatic enrollment
But, what about SECURE Act 2.0?
As provisions of SECURE 2.0 continue to become effective, it’s important to be aware of those that are applicable for the (calendar) 2025 plan year. Working with your third-party administrator and internal committees now will continue to ensure compliance with these provisions:
- Mandatory auto-enrollment
- If your 401(k) plan was established after December 29, 2022, the plan is required to implement an automatic enrollment provision for plan years beginning after December 31, 2024 (i.e. calendar 2025).
- Further information regarding plan establishment criteria can be found in IRS Notice 2024-2.
- Further considerations include working with your payroll providers and third-party administrators to ensure you have procedures in place to handle and process any opt-out requests for those not wishing to enroll in the plan
- Further information regarding plan establishment criteria can be found in IRS Notice 2024-2.
- If your 401(k) plan was established after December 29, 2022, the plan is required to implement an automatic enrollment provision for plan years beginning after December 31, 2024 (i.e. calendar 2025).
- Catch-up contribution increases
- For those participants who will attain ages 50 and over before the end of the plan year, the catch-up contribution remains at $7,500 (unchanged from 2024)
- However, for those participants who will attain ages 60-63 before the end of 2025, the maximum catch-up limit is increased to the greater of $10,000 or 150% of the regular catch-up contribution of $7,500 (i.e. $11,250).
- For those participants who will attain ages 50 and over before the end of the plan year, the catch-up contribution remains at $7,500 (unchanged from 2024)
Keep an eye on Meaden & Moore’s blog for future employee benefit plan content important to your compliance efforts or contact us today. for more details.
