On April 4, the U.S. Department of Labor (DOL) released guidance and updated model notices for annual funding notices (AFNs) required under ERISA. This update comes just weeks before the April 30, 2025 deadline for many defined benefit plans and places plan sponsors in a time crunch.
While the DOL acknowledges the late timing of this guidance, and that plan sponsors may have already prepared AFNs for the 2024 plan year, it has not granted any grace period or extension. Plan sponsors are expected to make a good faith effort to comply with the new requirements.
What plan sponsors need to do now:
To stay compliant with the latest DOL rules, plan sponsors should take the following steps:
- Check with your service providers to ensure your AFN complies with the new model notice. Note: Use of the DOL’s model notice is not mandatory, but your AFN must include all required disclosures.
- Send the updated 2024 AFNs to participants by the deadline:
- April 30, 2025, for most plans
- Sept. 15, 2025, for small plans (fewer than 100 participants)
Access the new guidance and model notices here:
If you have any questions about the new DOL annual funding notice requirements or would like assistance reviewing your 2024 AFN, our employee benefits and ERISA compliance team is here to help.
