Labor Eases Penalties in Delinquent Filer Compliance Program
Published Date: 12/31/2025
Notice
Summary
Starting December 31, 2025, the Department of Labor is updating its Delinquent Filer Voluntary Compliance Program to offer lower penalties for certain plan administrators who missed filing their required reports. This change helps administrators of different types of health and welfare plans avoid big fines by encouraging them to catch up on paperwork. If you manage these plans, now’s the time to get compliant and save money!
Analyzed Economic Effects
6 provisions identified: 2 benefits, 3 costs, 1 mixed.
Flat $750 Penalty for Late Form M-1 Filers
Under the modified DFVC Program, administrators of MEWAs and ECEs who file a complete Form M-1 for the most recent filing year can pay a $750.00 flat penalty via the Department's gov.pay web payment link to resolve the late filing. Top hat and apprenticeship and training plans that qualify for a flat fee will also use the gov.pay site.
Program Expanded to MEWAs and ECEs
Starting December 31, 2025, the Delinquent Filer Voluntary Compliance (DFVC) Program now covers plan MEWAs, non-plan MEWAs, and Entities Claiming Exception (ECEs) that are required to file Form M-1. If you administer one of these arrangements, you may be eligible to use the DFVC Program to resolve late Form M-1 filing obligations.
Personal Liability — No Plan Asset Payments
Penalties paid under the DFVC Program are the personal liability of the MEWA or ECE administrator and may not be paid from the assets of an employee benefit plan. If you are an administrator, you cannot use plan funds to make the $750 payment.
Timing and Limits on Eligibility and Relief
The DFVC Program is available only if the MEWA or ECE administrator files and pays under Section 3 or 4 before the administrator is notified in writing by the Department of a failure to file. The Program does not provide relief for penalties assessed for reports the Department determines to be incomplete or otherwise deficient.
Electronic Payment and Filing Requirement
To use the DFVC Program for Form M-1, you must file a complete Form M-1 electronically in accordance with EFAST rules and pay the $750 penalty by electronic payment through the Department's gov.pay link. The filing requirement applies to the most recent filing year.
Waiver of Notice and Contest Rights on Payment
If you pay a penalty under the DFVC Program for the late filings submitted under the Program, you waive your right to receive the Department's notice of intent to assess a penalty under 29 CFR 2560.502c-2 and 2560.502c-5 and you waive the right to contest the Department's assessment of the penalty amount.
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