The Pension Benefit Guaranty Corporation (PBGC) issued Technical Update No. 26-1 on September 18, 2026, which waives on a prospective basis the requirement to report an attrition event under the agency’s reportable events regulation, which can be found at 29 CFR Part 4043.
Attrition events can arise from any number of situations, but in recent years have been occurring more frequently in frozen defined benefit plans that have few active participants. Under the regulation, a plan sponsor is obligated to notify the PBGC when the number of active participants drops below 80% of the number at the beginning of the current plan year. The PBGC has found, however, that attrition events rarely identify circumstances warranting additional agency reviews.
The Technical Update waives the obligation to report attrition events, but not single-cause events or other reportable events under the PBGC’s reportable events regulation. Single-cause events can happen at any time and may be the result of a reorganization or restructuring, the discontinuance of an operation or business, a natural disaster, a mass layoff, or an early retirement incentive program, among other things. A plan sponsor must still monitor and report these types of single-cause events, as well as other reportable events (such as controlled group changes, loan defaults, etc.) as applicable.
The requirement to report an attrition event under 29 CFR § 4043.23(a)(2) is waived if the deadline for reporting it occurs on or after September 18, 2026. Although the waiver is temporary, it will remain in effect until PBGC issues a final regulation amending § 4043.23 with respect to attrition events.
If you have any questions about the Technical Update or any of the PBGC’s reportable events, please contact the authors of this blog post or your regular Morgan Lewis contact.