DOL Notice: Transition to Electronic Payments and Disbursements (Aug. 22, 2025), 90 Fed. Reg. 41843 (Aug. 27, 2025) Available at https://www.govinfo.gov/content/pkg/FR-2025-08-27/pdf/2025-16426.pdf
The DOL has announced that, effective September 30, 2025, it will no longer accept paper checks as a form of payment. It will also cease issuing paper checks. An executive order on modernizing payments to and from the federal government prompted the change, which the DOL says will “improve efficiency in processing payments and reduce administrative burdens.”
EBIA Comment: ERISA plans face relatively few instances that involve mailing checks to the DOL. Currently, penalties under the DOL’s Delinquent Filer Voluntary Compliance (DFVC) Program for Form 5500 filing failures may be paid electronically or via mail. After September 30, filers should plan to pay these penalties using the DFVC Penalty Calculator and online payment system; the webpage has been updated to reflect that paper checks will no longer be accepted. For more information, see EBIA’s ERISA Compliance manual at Section XXXII.B (“Correcting Late and Unfiled Form 5500s: Delinquent Filer Voluntary Compliance Program”) and EBIA’s 401(k) Plans manual at Section XXXI.I (“DFVC Program Using EFAST2”). See also EBIA’s Self-Insured Health Plans manual at Section XXII.F.1 (“Form 5500 Compliance Failures”).
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