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2026 Reporting and disclosure requirements under ongoing calendar-year qualified plans

January 7, 2026

This article provides reporting and disclosure requirements under ongoing calendar-year qualified plans in the United States.

Reporting requirements*

2026 reporting requirements
Item Description Recipient Due date
Form 1099-R Report of distributions from pensions, annuities, retirement or profit-sharing plans, IRAs, insurance contracts, etc. IRS and payees 2/2/2026* payees
3/2/2026* (3/31/2026 if filed electronically)
additional 30 days available if extension requested
Form 11-K Annual report required where employee contributions may be invested in company stock SEC 6/29/2026 (for ERISA plans)
Form 5558 Application for extension of time to file Form 5500 and/or Form 8955-SSA; extension up to 2½ months after the normal due date. Not required if filer uses automatic extension to 10/15/2026, i.e., plan year and employer tax year are the same and employer is granted extension for tax return IRS DOL (if filed electronically) 7/31/2026
Form 5500 (including applicable schedules and attachments) Annual return/report of employee benefit plan DOL 7/31/2026
(10/15/2026 if extension applies)
Form 8955-SSA Annual statement identifying participants with deferred vested benefits IRS 7/31/2026
(10/15/2026 if extension applies)
Comprehensive
PBGC premium filing 		Flat-rate premium payment and variable-rate premium payment PBGC 10/15/2026 (variable-rate premium can be an estimate with true-up by 4/30/2027 if certain conditions are met)
PBGC reporting for
underfunded plans 		Annual reporting of financial and actuarial information. Required when any plan in the controlled group has a funding ratio below 80%** PBGC 4/15/2026 (if all nonexempt controlled group members have the same non-calendar fiscal year, 105 days (106 days in leap years) after close of fiscal year). Separate, additional reporting required within 10 days of missed contributions exceeding $1 million in the aggregate

*The IRS, DOL, PBGC and SEC, as applicable, extend the filing due date to the following business day when the due date falls on a weekend or holiday.
**The PBGC waives reporting if the aggregate underfunding of the controlled group’s underfunded defined benefit plans does not exceed $15 million.

Disclosure requirements*

2026 disclosure requirements
Item Description Recipient Due date
Summary of material modifications Summary of any material change to SPD information adopted in 2025 Participants and beneficiaries 7/29/2026
Summary annual report Summary information on plan’s financial activities as reported on Form 5500 (not applicable to defined benefit plans subject to Title IV of ERISA) Participants and beneficiaries 9/30/2026 or two months after Form 5500 is due, if later
Summary plan description Summary of plan in easily understandable language Participants and beneficiaries Within 90 days after individual becomes a participant and within 90 days after beneficiary first receives benefits.
Updated SPD every five years if changes are made; otherwise every 10 years.
Participant benefit statement Statement including participant’s total accrued benefit, vested benefit, and certain other information DC plans: participants and beneficiaries DC plans: within 45 days of the end of each calendar quarter if participant directs investments; otherwise annually by date 5500 is filed for plan year to which statement relates but not later than due date of such 5500
DB plans: active participants (including actives with frozen benefits) DB plans: every three years or provide annual notice of availability
Annual funding notice Notice of plan’s funding status. Required for defined benefit plans subject to Title IV of ERISA Participants, beneficiaries, labor organizations (if applicable), PBGC (if more than $50 million underfunded) 4/30/2026
Small plans with 100 or fewer participants, counting all defined benefit plans in the controlled group, have additional time to furnish (until the Form 5500 is filed, or the due date (with extensions) for the Form 5500 if earlier)
Rollover notice Explanation of direct rollover option and related federal income tax rules Recipients of eligible rollover distributions Generally, not less than 30 and not more than 180 days before the date of distribution; 30 days may be waived by recipient
Optional forms explanation Explanation of payment options, right to defer, and consequences of not deferring Recipients of distributions Generally, not less than 30 and not more than 180 days before the date of distribution; 30 days may be waived by recipient
QJSA notice Written explanation of qualified joint and survivor annuity provisions, relative values and election procedures. Required for plans subject to joint and survivor rules (generally, defined benefit and money purchase pension plans) Participants Generally, not less than 30 and not more than 180 days before the annuity starting date; 30 days may be waived by recipient
QPSA notice Written explanation of plan’s qualified preretirement survivor annuity provisions. May be required for plans subject to joint and survivor rules (generally, defined benefit and money purchase pension plans). Most plans are designed to be exempt from this notice requirement Participants Generally, between first day of plan year in which participant reaches age 32 and end of plan year prior to attaining age 35, or one year after the individual becomes a participant, if later
Suspension of benefits notice Explanation of why benefit payments are being suspended upon reemployment or continued employment after reaching normal retirement age Participants who commenced receiving benefit payments that are suspended because of reemployment or who continue working after their normal retirement age and do not commence benefit payments During the first calendar month or payroll period in which benefits are suspended

*The DOL does not have an official policy extending the due date for disclosures to the following business day if the date falls on a weekend or holiday.

This summary chart focuses on the most typical reporting and disclosure requirements and is for informational purposes only. It should not be used as a substitute for legal, accounting, actuarial or other professional advice.

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Contacts

Stephen Douglas
Stephen Douglas
Senior Director, Retirement and Executive Compensation
Email+1 203 326 6315
William "Bill" Kalten
William “Bill” Kalten
Senior Director, Retirement and Executive Compensation
Email+1 203 326 4625
Tristan Christ, U.S. Retirement Resource Actuary
Tristan Christ
U.S. Retirement Resource Actuary
Email+1 952 842 6717
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