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Deadlines
Treasury and the IRS proposed rules defining what a Trump Account can hold before the beneficiary turns 18: generally an unleveraged mutual fund or ETF tracking a broad U.S. equity index such as the S&P 500, charging no more than 0.1 percent in annual fees, with the trustee selecting a default fund when no election is made. The August 11 rules told employers what they may contribute; this one tells trustees what the money may sit in. Comments are due October 20, 2026.
Foley's reminder that years of CARES, SECURE, and SECURE 2.0 operation may not yet be reflected in plan documents: when operations, communications, and the document diverge, the amendment deadline is the cleanup moment. A practical December 31 checklist starter.
The IRS proposed the first comprehensive update to the section 430 minimum-funding regulations in years, finally implementing amendments from WRERA, SECURE, and SECURE 2.0. The substantive changes actuaries will care about: investment management expenses are excluded from target normal cost, with a $5,000 threshold mirroring Schedule C itemization; plans adopted after year-end but before the return due date count as adopted on the last day of the year for funding purposes; and benefit-increasing amendments adopted after the valuation date can enter the funding math if they pass a new disproportionality test. Comments are due October 19, and the rules would apply to plan years beginning six months after finalization, with earlier reliance permitted.
Aon's Compliance and Policy Consulting team digs into the DCAP half of the August 11 proposed regulations: clarified nondiscrimination testing that should raise passing rates, especially on the average benefits test, where only employees actually contributing are counted and workers earning under $25,000 may be excluded. Employers may rely on the proposed rules for 2026 plan-year testing now. Comments are due September 25, with a public hearing set for October 15.
Groom walks through the DOL's proposed e-delivery safe harbor for group health plans: who counts as a covered individual, the notice-of-internet-availability mechanics, and where the proposal diverges from the 2020 retirement-plan framework. Comments are due September 21.
Illinois amended its Human Rights Act on August 7 to establish workplace protections for employees experiencing menopause-related conditions, effective January 1, 2027, and reaching employers with a single Illinois employee. Littler on the compliance build-out between now and the effective date.
Jackson Lewis on the same statute from the accommodation side: Illinois joins Rhode Island and Philadelphia in making menopause-related conditions a protected status, and employers should review handbooks, leave policies, and benefit designs before the January effective date.
Implementing SECURE 2.0 section 324, the IRS proposes four optional sample forms and standardized procedures for rollovers between employer plans or between a plan and an IRA, aiming to replace today's paper-check-and-fax friction with a predictable process. Use of the forms would be optional and no safe harbor attaches yet; comments are due October 23, 2026.
Treasury and the IRS proposed the framework for employer Trump account contribution programs: a separate written plan, eligibility classes tested under DCAP-style nondiscrimination rules including a 90% sliding-scale safe harbor, written employee notification, and W-2 reporting, with employees able to exclude up to $2,500 per year of employer contributions. The proposal also updates the section 129 DCAP nondiscrimination rules themselves, reflecting the OBBBA's increase of the dependent care exclusion to $7,500. Employers may rely on the proposed rules now; comments are due September 25 and a public hearing is set for October 15.
As the December 31, 2026 deadline approaches for adopting SECURE and SECURE 2.0 amendments, Milliman examines a key decision for defined benefit plan sponsors: whether to retain a required start date for benefit distributions that is earlier than the new later statutory required beginning date for RMDs, which has been raised to age 72, 73, and 75 depending on the participant's birth year.
The IRS intends to issue opinion letters on August 31, 2026 for Cycle 4 defined contribution pre-approved plans updated for the 2023 Cumulative List. The announcement also sets the employer adoption deadline and the determination letter application window for adopting employers.
CMS reopened the HHS-administered federal external review process effective July 31 after a month of unavailability. Consumers whose deadline to request external review fell between July 1 and August 3 now have until October 2, 2026 to file. Relevant to plans that elected the HHS process (AL, FL, GA, WI, TX and territories) and self-insured non-federal governmental plans with live claim appeals.
As the SECURE 2.0 Act deadline for mandatory catch-up contributions for some plan participants looms, many retirement plan sponsors are beginning to amend their plan documents to meet its requirements.
Retirement plans face a critical compliance deadline arriving on December 31, 2026.
Virginia Governor Abigail Spanberger recently signed into law paid sick leave (PSL) entitlements for nearly all employees working in the Commonwealth. The law will have a staggered effective date, with the earliest changes taking effect in mid-2027.
Virginia Governor Abigail Spanberger recently signed into law paid sick leave (PSL) entitlements for nearly all employees working in the Commonwealth. The law will have a staggered effective date, with the earliest changes taking effect in mid-2027.
The U.S. Supreme Court recently ruled that the Employee Retirement Income Security Act (ERISA) does not require multiemployer pension plans to use actuarial assumptions to calculate withdrawal liability adopted before a certain deadline.
Effective July 4, 2026, employers may contribute up to $2,500 annually on a tax-free basis to “Trump Accounts,” a new tax-advantaged savings account for employees’ dependent children under age 18, which was established under the Working Families Tax Cuts Act (Pub.
The December 31, 2026 deadline is fast approaching for most non-governmental plan sponsors to amend their tax-qualified retirement plans to comply with changes made by the SECURE Act of 2019, the CARES Act, the Taxpayer Certainty and Disaster Relief Act of 2021, and the Secure 2.0 Act (the “Acts”).
As a reminder, the deadline for submitting Patient-Centered Outcomes Research Institute (PCORI) fees is July 31. Employers that sponsor self-insured group health plans should use the most current revision of IRS Form 720, Quarterly Federal Excise Tax Return, to report and pay the fees.
The deadline to adopt a restated pre-approved 403(b) plan is rapidly approaching. Here's what employers need to know.
Effective July 1, 2026, government contractors in Illinois who perform prevailing wage work must afford apprentices fringe benefits. These fringe benefits include pensions, vacations, and training, among other things
If your organization sponsors a pre-approved 403(b) plan, an important compliance deadline looms on the horizon.