Several recent and proposed changes will impact how labor organizations administer and report on employee benefit plans. Here are three key developments to keep on your radar as you plan for 2026 and beyond:
1. PBGC Eliminates Paper Checks for Premium Payments
The Pension Benefit Guaranty Corporation (PBGC) is requiring all premium payments to be made electronically (ACH or Fedwire) for plan years beginning in 2026. After June 30, 2026, any paper checks received will be returned or destroyed, potentially resulting in late fees or penalties. In addition, refunds and overpayments will no longer be issued via paper check and will instead be processed through electronic funds transfer (EFT).
The shift is part of a broader federal push toward electronic payments, which are considered more secure and significantly less prone to delays than paper checks.
What Does This Mean?
Organizations should transition payment processes now and ensure access to My PAA or Pay.gov, while also aligning internal workflows for both outgoing payments and incoming refunds.
2. Updated Draft Form 8955-SSA Released
The IRS’s updated draft of Form 8955-SSA (Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits) introduces a continued emphasis on electronic filing. Filers submitting 10 or more returns of any type during the calendar year are now required to e-file.
The draft also reinforces key reporting practices, including:
- Using “Entry Code B” to correct or remove previously reported participants who have since received full distributions (a “de-reporting” process)
- Applying “Entry Code C” when benefits are transferred to a new employer’s plan (or “A” if prior plan information is unavailable)
- Providing expanded plan sponsor details, including “in care of” names and foreign address fields
- A strict no-attachments policy, prohibiting supplemental spreadsheets or external documentation
What Does This Mean?
Accurate participant tracking and clean data management are critical. Plan administrators should review how they handle distributions, transfers, and corrections to ensure compliance with updated reporting expectations.
3. Draft 2026 Form 1099-R Changes
The draft 2026 Form 1099-R introduces new reporting boxes designed to provide greater visibility into retirement distributions:
- Box 7b: Identifies IRA, SEP, or SIMPLE plan distributions
- Box 7c: Adds a checkbox for “Trump Account” reporting
- Box 7d: Captures earnings on excess contributions
The form continues to apply broadly to distributions from pensions, annuities, IRAs, and profit-sharing plans, generally at a $10 threshold. Recipients may still receive multiple Forms 1099-R if they have different types of distributions, each tied to specific distribution codes.
Additionally, there is a notable threshold change: beginning in 2026, the minimum reporting threshold for certain information returns will increase to $2,000, with future inflation adjustments expected. Additionally, digital assets tied to real estate transactions will shift to Form 1099-S reporting rather than 1099-R.
What Does This Mean?
These updates may require system and process adjustments to capture new data points and ensure proper classification of distributions across plan types.
Looking Ahead
These updates reflect a broader trend toward digitization, increased transparency, and tighter reporting standards. For labor organizations managing employee benefit plans, now is the time to evaluate administrative processes, strengthen data accuracy, and prepare systems for evolving compliance requirements.
If you have any questions or are interested in learning more, we are here to help. Please do not hesitate to reach out to discuss your specific situation.
This material has been prepared for general, informational purposes only and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. Should you require any such advice, please contact us directly. The information contained herein does not create, and your review or use of the information does not constitute, an accountant-client relationship.
