Beginning January 1, 2024, users of the DOL’s EFAST filing system will be required to access EFAST using login.gov. Consequently, existing users will need to create an account on login.gov that can be linked to an existing EFAST account. (This change will not affect users that file using approved private software.)

This year, the PBGC is expected to adopt the login.gov sign-on system for its e-Filing Portal. The PBGC will contact users who have existing e-Filing accounts about the change.

The PBGC has already adopted the login.gov sign-on system for its My Plan Administration Account (My PAA). The change to the login.gov sign-on system for My PAA was effective November 21, 2022.

Background

On May 12, 2021, President Biden issued Executive Order 14028, “Improving the Nation’s Cybersecurity,” which directs federal agencies to improve cybersecurity practices and software supply chain integrity. Among other actions, agencies are required to deploy multifactor authentication and encryption in public-facing websites.

The login.gov secure single sign-on system is intended to satisfy the mandates of EO 14028.

Effect on PBGC filings and payments

Defined benefit plans electronically submit PBGC premium filings, payments and certain requests using My Plan Administration Account (My PAA).

Other filings are submitted via the PBGC e-Filing Portal. Sponsors of multiemployer DB plans can use the e-Filing Portal to submit:

• The annual funding notice
• Notices of endangered or critical status
• Information on withdrawal liability and actuarial valuation, if the plan is terminated by mass withdrawal or by plan amendment and expected to become insolvent, if the plan is insolvent and receiving financial assistance from PBGC
• Notices of termination, if the plan has terminated as described in section 4041A(a) of ERISA
• Notices of insolvency, if the plan terminates by mass withdrawal, or if the plan is insolvent in the current plan year or expected to be insolvent in the next plan year
• Notices of insolvency benefit level, if the plan experiences a change in insolvency benefit level that affects participants and beneficiaries in pay status or expected to enter pay status
• Applications for financial assistance
• Applications for Special Financial Assistance (SFA)
• Annual Statements of Compliance (for plans that have received SFA)

Sponsors of single-employer DB plans can use the e-Filing Portal to submit:

• 4010 Filings
• Form 10
• Form10-Advance
• Form 200
• Documents required for settlement agreements

Implications for plan sponsors

Plan sponsors that e-file Form 5500 with the DOL and/or use the PBGC’s e-Filing Portal will need to create a Login.gov username and password. As a reminder, since January 1, 2009, Form 8955-SSA is filed with the IRS and not as an attachment to the Form 5500.

Other federal agencies are gradually adopting the new system as it adds capacity.