Employee Benefit Plan Advisories

Key Employee Benefit Plan Reporting Deadlines: What Plan Administrators Need to Know for the Second Half of the Year

September 16, 2026
Claudia Perry

Article | by Geffen Mesher

Managing an employee benefit plan comes with a steady stream of compliance obligations, and the second half of the calendar year is among the busiest stretches for plan administrators. From funding notices to annual filings, missing a deadline can trigger penalties, participant complaints, and regulatory scrutiny — putting both your organization and your employees’ retirement savings at risk. At Geffen Mesher, we work alongside plan administrators year-round to keep those obligations on track, giving you and your employees confidence that their retirement savings are in trusted hands.

 Below is a practical breakdown of the major reporting and disclosure deadlines that fall in August and beyond, so your team can stay ahead of its obligations.

 

Note: The deadlines below are based on calendar-year plans. If your plan operates on a fiscal year, adjust accordingly. This overview addresses ERISA Title I and Title IV requirements; it does not cover all IRS notice requirements. Consult your plan administrator, legal counsel, or a qualified CPA for guidance specific to your plan.

July 

Form 5500 Annual Return/Report – July 31

The due date for Form 5500 and audited financial statements (if required) are due by the last day of the 7th month after plan year end. Most plan administrators can file for an extension, pushing the deadline to October 15 ( or, an additional 2.5 months).  Contact us if you are unsure if your plan meets the requirements for an audit.

September

Summary Annual Report (SAR) – September 30

The SAR is a narrative summary of the plan’s Form 5500 filing and must be distributed to participants and beneficiaries currently receiving benefits. The SAR is generally due within 9 months after plan year end, however, if the plan received an approved extension for its Form 5500 filing, the SAR is due within 2 months after that extended due date. 

October

Form 5500 Extended Deadline — October 15

For calendar-year plans that filed for an extension, this is the hard deadline for submitting the Form 5500 and audited financial statemetns (if required) or Form 5500-SF. 

Pension Benefit Guaranty Corporation (PBGC) Comprehensive Premium Filing – October 15

For defined benefit plans covered by PBGC insurance, the Comprehensive Premium Filing is generally due on this day as well. 

December

Qualified Default Investment Alternative (QDIA) Notice — December 1

For 401(k)-type plans with automatic enrollment or a QDIA, the annual QDIA notice must be delivered to participants at least 30 days before the start of each plan year.

Summary Annual Report (SAR) Following Extended Form 5500 – December 15

If your plan received an extension and files its Form 5500 by October 15, the SAR must be distributed to participants by this date (or two months after the extension).

Automatic Contribution Arrangement Notice — Within a Reasonable Period Before the Plan Year

Similar to the QDIA notice, plans with automatic contribution arrangements must provide participants with a notice of their rights and obligations within a reasonable period before the start of the plan year. The initial notice for a new plan or as a newly adopted provision must be provided at least 30 day, but not more than 90 days before eligibility. For calendar-year plans, late November is the typical target window.

Stay Ahead of the Deadlines

Employee benefit plan compliance is complex, and the stakes are high. Missed filings can result in civil penalties from the Department of Labor, excise taxes from the IRS, and PBGC penalties — not to mention the reputational risk with plan participants.

At Geffen Mesher, our Employee Benefit Plan Services team works with plan administrators year-round to ensure audits are completed on time, disclosures are prepared accurately, and filings meet regulatory standards. If you have questions about your plan’s compliance obligations or want a second opinion on your current processes, we are here to help.

 

Geffen Mesher’s team is available to assist you with questions related to these updated rules. Please contact professionals for more information at INFO@GMCO.COM.

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