The 2025 filing dates

The PBGC guidance (PBGC Technical Update Number 25-1, which as issued on January 6, 2025) notes that under the one-time change, each due date is moved up by one month. Thus, for calendar-year plans, the premiums for the 2025 plan year are due September 15, 2025 rather than October 15, 2025.

The 2025 filing dates are as follows:

It’s possible these 2025 filing dates might change

The PBGC guidance explains that presidential budget requests since BBA2015 have asked that the change be repealed and the date moved back to the original date (e.g., October 15, 2025). The notes that movement of the date is still possible. If that happens, the PBGC will notify payers and revise premium filing instructions.

Next steps

Unless and until the law is changed, the one-month earlier date (e.g., September 15, 2025 for calendar-year plans) applies for 2025 premium filings.

Plans should not rely on the date being changed back given the ups and downs of the legislative process. Items that are included in preliminary bills can be dropped by the final, and vice versa.

We will keep you informed of any change.

2026 filings

Filings for the 2026 plan year revert to the normal schedule. Consequently, the 2026 premium filing date for calendar-year plans will be October 15, 2026.