In the pension world there are a lot of dates to remember – plan year ends, deadlines for making correcting testing failures, Form 5500 filing due dates (with and without extension) just to name a few.

In the CB world there are a few more, most notably September 15. 

[To be precise, it is the date 8½ months after the close of the plan year but for simplicity (and because this is most common) we assume a calendar plan year and therefore September 15.]

September 15 is the Due Date for Plan Contributions

Most importantly, September 15 is the date by which contributions for the prior plan year are due.  Failure to make the full minimum required contribution by September 15 will result in a 10% excise tax on the unpaid amount. 

This excise tax must be paid by the plan sponsor; it cannot be paid from plan assets. And the required contribution still remains due; it is not replaced by the excise tax.

The September 15 date is not tied to the due date of the plan sponsor’s tax return.  It is a common mistake for plan sponsors with tax returns extended to October 15 (generally sole proprietors & partnerships) to assume that they have until October 15 to make the required contribution only to discover that they missed the September 15 deadline and the 10% excise tax applies.

You may want to reach out to your CB clients now to make sure they are aware of the deadline and are prepared to make their contribution by September 15.

September 15 is the Practical Deadline for Retroactive Plan Adoption

While the SECURE Act permits plans to be retroactively adopted for the prior year if done so by the extended due date of the plan sponsor’s tax return, the deadline for making minimum required contributions to a CB plan for the prior plan year is still September 15. 

This means that not only must the decision to adopt the plan be made by September 15 but that all the steps necessary to establish and fund the plan must be completed as well.  These include preparing and adopting the plan document, setting up the account to hold plan assets and preparation of the actuarial valuation by the plan’s actuary.  The making of the contribution by the plan sponsor is the last step in this process.

It is not uncommon for TPAs and other service providers to have cut off dates in July or August for the installation of retroactively adopted plans so be sure to talk to your provider.

A cash balance plan is a serious commitment that should not be taken without appropriate consideration.  The earlier the plan design and decision-making process is started the better.

September 15 is PBGC Premium Due Date for 2025

Unlike Forms 5500 which are filed after the close of the plan year, PBGC premium filings & payments are due during the plan year.  Forms 5500 are due (with extension) 9½ months after the close of the plan year.  PBGC premiums are payable by 9½ months after the beginning of the plan year. 

In both cases, the due date is October 15 (assuming calendar plan years) but the rules/regs which produce the October 15 dates are unrelated.

For 2025 (and 2025 only), the rules/regs which determine the PBGC filing & premium due date have been changed*.  PBGC premium filings & payment are due 8½ months after the beginning of the 2025 year which means (assuming calendar plan year) that premium filings & payments are due September 15.

Failure to file and pay premiums timely triggers a late payment penalty plus interest charges on the unpaid amount so it is important for you and your clients to be aware of this accelerated due date.

This is likely to be a point of confusion for 2025 since many clients have simply assumed the Form 5500 and PBGC due dates were the same.

Be sure your CB clients are aware of this special early payment and filing date.

[Note: not all CB plans are covered by the PBGC; ask your actuary or TPA if you are not sure about whether the plan is covered.]

*This one time accelerated due date is due to a provision of the Bipartisan Budget Act of 2015 which accelerated the 2025 due date so that premium revenue could be recognized in budget scoring during the 10 year budget window.

Thinking about offering DB or CB plans but don’t want the actuarial headache? Aegis Pension Services handles the heavy lifting: design, testing, and admin so you don’t have to.
Like many top TPAs, we use Stax.ai to streamline the process. It automates data collection, compliance, and client follow-up so we can focus on the numbers and you can expand your services without the overhead.