To alleviate plan sponsor financial burdens during the height of the coronavirus (COVID-19) pandemic, Section 3608 of the CARES Act delayed the due date for required minimum contributions for defined benefit pension plans otherwise due in 2020. The delayed payments, plus interest for the period of the delay using the plan’s effective interest rate, are due on or before January 1, 2021. The January 1, 2021 deadline applies notwithstanding that it is a legal holiday.
If delayed payments (plus applicable interest) are not made by January 1, 2021, penalties will apply as of January 1, 2021. Specifically, excise taxes will apply to unpaid final required contributions for the 2019 plan year (originally due on September 15 for calendar year plans). Missed quarterly contributions for the 2020 plan year are not subject to excise taxes, but will incur an additional 5% interest on the delayed payments.
To avoid incurring penalties, plan sponsors that delayed required minimum contributions in 2020 should ensure that delayed payments are made on or before January 1, 2021.