Under the Bipartisan Budget Act of 2015 ("BBA 2015"), Pension Benefit Guaranty Corporation ("PBGC") premiums for plan years beginning in 2025 are due one month earlier than normal. For example, for calendar year plans, premiums are due on September 15, 2025 rather than October 15, 2025. This one-month acceleration had the effect of raising revenue, because it pulled one more year of PBGC premiums into the Congressional 10-year window for budget scoring purposes.
On January 6, 2025, the PBGC issued Technical Update 25-1, which confirms that, for plan years beginning in 2025, the premium filing and payment due date is the 15th day of the 9th calendar month that begins on or after the first day of the plan year. The Technical Update notes that, for the past eight years, the President's Budget has called for the repeal of this change in order to prevent plan sponsors from incurring unnecessary costs and burdens in preparing and making the accelerated premium payments. However, as it now stands, the one-month acceleration for 2025 is still in effect.
It remains possible that Congress could take action to repeal the accelerated premium due date for 2025. However, as of now, PBGC premiums will be due one month earlier than usual for the 2025 plan year. Defined benefit plan sponsors should be aware of this change and should plan to make PBGC premium payments one month earlier than in previous plan years.
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