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2021 Compliance Calendar



Provide/Confirm prior year census data



Deadline: Sending Form 1099-R to participants who received distributions during previous year*



Review/Approve compliance testing results



Deadline: Filing Form 1099-R with IRS to report distributions made in previous year Deadline for electronic filing is March 31*



Deadline: ADP/ACP test corrective distributions to avoid excise taxes, unless EACA for full year 2019


Note: A special deadline may apply to plans that satisfy the requirements of an eligible automatic contribution arrangement (EACA). See “June”


Deadline: Filing partnership tax returns and contribution deadline for deductibility (without extension) for companies operating on calendar0year fiscal year


Deadline: Requesting automatic extension to September 15 for partnership tax returns



Deadline: Electronic filing of Form 1099-R to report distributions made in previous year



Required: Beginning date for participants attaining age 72 or retiring after age 72 in prior year


Deadline: Taking first required minimum distribution (RMD) under Internal Revenue Code (IRC) Section 401(a)(9)**



Deadline: Processing corrective distributions for IRC Section 402(g) excesses


Deadline: Filing individual tax returns


Deadline: Contribution deadline for deductibility for self-employed individuals (without extension)


Deadline: Requesting automatic extension to October 15 for individual and corporate tax returns



Deadline: processing corrective distributions for failed ADP/ACP test from plan with EACA without 10% excise tax (if applicable)



Deadline: Sending Summary of Material Modification (SMM) (210 days after end of plan year in which the amendment was adopted)



Deadline: Filing Form 5500 (without extension)


Deadline: Filing Form 5558 to request automatic extension of time to file Form 5500 (to October 15)


Deadline: Filing Form 5330—Return of Excise Taxes Related to Employee Benefit Plans-used to report and pay excise taxes on prohibited transactions and excess 401(k) plan contributions that occurred in prior year



Extended deadline: Filing tax returns for partnerships


Final deadline: Contribution deadline for deductibility for calendar-year partnerships and S-corporations



Deadline: Distributing Summary Annual Report (SAR) to participants, unless deadline for Form 5500 was extended, then two months after due date for Form 5500 (December 15)



Deadline: Adopting a retroactive amendment to correct an IRC Section 410(b) coverage or IRC Section 401(a)(4) nondiscrimination failure


Extended deadline: Filing Form 5500


Extended deadline: Individual and/ or corporate tax returns and final contribution deadline for deductibility for these entities



Deadline: Sending annual 401(k) and safe harbor match notice


Deadline: Sending annual QDIA, qualified default investment alternative notice


Deadline: Sending annual automatic contribution arrangement notice (ACA)
For administrative ease, a combined notice may be provided for the above notices



Extended deadline: Distributing SAR to participants



Deadline: Processing corrective distributions for failed ADP/ACP test with 10% excise tax


Deadline: Correcting a failed ADP/ACP test with qualified nonelective contributions (QNECs)


Deadline: Amendment to convert existing 401(k) plan to safe harbor design for next plan year (provided notice requirement is met)


Deadline: Amendment to remove safe harbor status for next plan year


Deadline: Amending plan for discretionary changes implemented during plan year (certain exceptions apply)

*The deadlines in this calendar are for plans with calendar-year plan years.


**The CARES Act provides a waiver of RMD’s for defined contribution plans and IRAs for 2020.

Reminder: Required fee disclosures

Plan Sponsor

Initial disclosure: Required within a reasonable period before the contract is entered into or renewed

Annual disclosure: Required following changes in investment information

Additional disclosures: Required no later than 60 days after the effective date of the change for changes in compensation or services provided


Initial disclosure: Required on or before the date when participants can first direct investments

Annual disclosure: Required to be updated and distributed at least annually

Additional disclosures: Required at least 30 days, but no more than 90 days, prior to certain plan changes

Highland maintains important disclosures about its status as a Registered Investment Advisor with the SEC in its Form ADV Part 2.


This information was developed as a general guide to educate plan sponsors and is not intended as authoritative guidance or tax/legal advice. Each plan has unique requirements and you should consult your attorney or tax advisor for guidance on your specific situation.