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, likely to allow the federal government to count an extra year of premium payments within their 10-year budget window.
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 | 2/16/2026* |
| 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 |
*Dates adjusted to the next business day if the due date 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 As a result, it is possible that this provision could be repealed during the 2025 federal fiscal year (October 1, 2024 – September 30, 2025).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.
Our 2025 calendars of key administrative dates and deadlines for calendar-year plans reflect the accelerated PBGC premium due date.
Please contact your Milliman consultant with any questions.
1 The PBGC administers two insurance programs covering most private-sector (i.e., non-governmental) DB plans, one for single-employer DB plans and one for multiemployer DB plans. Certain small professional service plans, plans covering only substantial owners, plans based in Puerto Rico, and certain church plans are not covered by the PBGC and do not pay premiums.