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.
Your PRIA Score
Personalized for You
How does this regulation affect your finances?
Sign up for a PRIA Policy Scan to see your personalized alignment score for this federal register document and every other regulation we track. We analyze your financial profile against policy provisions to show you exactly what matters to your wallet.
Key Dates
Department and Agencies
Related Federal Register Documents
2026-05492 — Retirement Security Rule: Definition of an Investment Advice Fiduciary: Notice of Court Vacatur
The court has canceled the Department of Labor’s 2024 rule that changed who counts as a trusted investment advisor for retirement plans. Starting April 20, 2026, the old rules from 2020 will be back in charge, affecting financial advisors and retirement plan managers. This means advisors should review their practices to stay on the right side of the law and avoid costly mistakes.
2025-14281 — Pooled Employer Plans: Big Plans for Small Businesses
Small businesses get a big boost with new guidance on pooled employer plans (PEPs), which help them offer better, cheaper retirement savings options. The government is asking for feedback to create clear rules that make joining these plans easier and more affordable. Starting soon, these changes aim to save workers money and help small employers attract great employees.
2026-06178 — Fiduciary Duties in Selecting Designated Investment Alternatives
The Department of Labor is proposing new rules to help those in charge of 401(k) plans pick smart investment options, including some alternative assets. This makes it clearer how to act responsibly and safely when choosing these investments, aiming to give more people access to different ways to grow their retirement money. Plan managers and investors should weigh in by June 1, 2026, as these changes could impact how retirement funds are handled and grown.
2026-05165 — Proposed Exemption From Certain Prohibited Transaction Restrictions Involving AT&T Inc. (Together With AT&T Inc.'s Affiliates, AT&T or the Applicant) Located in Dallas, Texas
The Department of Labor is considering a special rule change for AT&T and its affiliates in Dallas, Texas, that would adjust some financial transaction restrictions from 2013 through 2023. This change could affect how AT&T handles certain employee benefit transactions, with a chance for the public to comment or request a hearing by June 17, 2026. If approved, it updates past rules to better fit AT&T’s business needs without harming workers’ benefits.
2026-03827 — Exemption Involving the International Union of Operating Engineers Local Union 627 Training Fund of Oklahoma (the Plan or the Applicant) Located in Oklahoma City, OK
The International Union of Operating Engineers Local 627 Training Fund in Oklahoma City got the green light to borrow money at a low interest rate to buy heavy machinery. This deal, effective February 26, 2026, helps the fund grow while protecting its members’ interests. An independent expert will watch over the loan to keep everything fair and square.
2026-03826 — Exemption Involving the Liberty Latin America 401(k) Savings Plan (the Plan or the Applicant) Located in Denver, CO
The Liberty Latin America 401(k) Plan in Denver got a special green light to buy, hold, and sell certain stock rights from September 10 to 25, 2020. This means plan members could grab these rights for free and either sell them or buy discounted stock, helping their retirement savings. The Department of Labor reviewed and approved this move as fair and safe for everyone involved.
Previous / Next Documents
Previous: 2025-24081 — Accreditation and Approval of Thionville Surveying Company, Inc. (Harahan, LA), as a Commercial Gauger and Laboratory
Thionville Surveying Company in Harahan, LA, just got the green light to measure and test animal and vegetable oils for customs starting May 14, 2024. This means they’re officially trusted for the next three years, helping businesses with accurate oil inspections. If you deal with these oils, expect smoother customs checks and no extra fees right now.
Next: 2025-24083 — Approval of USA, Inc. (Wilmington, NC), as a Commercial Gauger
Great news! Intertek USA, Inc. in Wilmington, NC, is officially approved to measure petroleum products for U.S. Customs starting August 29, 2024, and will keep this role for three years. This means businesses dealing with petroleum can trust Intertek for accurate checks, helping smooth imports and exports without extra costs or delays. The next big check-up for Intertek will happen in August 2027.
Take It Personal
Get Your Personalized Policy View
Start a Free Government Policy Watch to see how policy affects your household, then upgrade to PRIA Full Coverage for year-round monitoring.
Already have an account? Sign in