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Alex Scharr is an associate in the Labor Department and is a member of the Employee Benefits & Executive Compensation Group.

Following up on our recent blog post, SECURE 2.0’s Required Changes to Annual Funding Notice Become Effective in 2025, the Department of Labor released Field Assistance Bulletin 2025-02 on April 3, which addresses compliance questions regarding the required changes to AFNs under SECURE 2.0 and includes two updated model AFNs incorporating these changes.[1]

SECURE 2.0 introduced many changes for retirement plans, including updated disclosure requirements for a defined benefit plan’s annual funding notice (AFN). These updated AFN disclosure requirements apply for all plan years beginning after December 31, 2023. For calendar-year defined benefit plans, the first AFNs subject to the revised requirements will be due by April 30

As described in further detail below, absent Congressional action, plan sponsors should take note that PBGC premium filings will generally be due one month earlier than usual for plan years beginning in 2025. This modification only applies for 2025.

Under ERISA Section 4007, the PBGC determines when premium filings—the submission of required data and payment

Last week, the U.S. Departments of Labor and Treasury issued a Joint Notice requiring the extension of certain benefit plan deadlines for individuals affected by Hurricanes Helene and Milton and Tropical Storm Helene.[1] The deadline extensions echo relief issued during the COVID-19 pandemic, but apply to a more limited group of individuals. The