2020-2021 Requirements & Deadlines In Response to COVID-19 Emergency Relief

A limited extension for filing Form 5500 has been granted in connection with the COVID-19 emergency. The relief, which applied under both Code and ERISA guidance was issued in April 2020. Form 5500 filings that would otherwise be due on or after April 1 were due July 15, 2020. The extension’s application to each of the plans has depended on the plan year. The extension automatically applied to Form 5500 filings for plan years that ended in September, October, or November 2019 because the regular due dates for these filings would be, respectively, April 30, June 1 (because May 31 is a Sunday), and June 30, 2020; these filings were due July 15, 2020. An extension beyond July 15, 2020, was still available, using Form 5558, but the 2-1/2 month extension period was measured from the regular due date rather than July 15. Ordinarily, Form 5558 must be filed by the regular due date; due to the automatic extension, filing Form 5558 by July 15, 2020, would appear to be acceptance. The COVID-19 automatic extension also has applied to Form 5500 deadlines that would fall within the relief window due to a previously filed extension reque*