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Reportable Events & Large Unpaid Contributions

Reportable Events and Large Unpaid Contributions



Section 4043 of ERISA requires that plan administrators and sponsors notify PBGC of the occurrence of certain events that may signal problems with a pension plan or business. PBGC's regulation on reportable events and large cumulative funding underpayments describes the events and notice requirements in detail (see 29 CFR Part 4043). PBGC also issues Technical Updates and other informal guidance about these events.

On April 3, 2013, PBGC published a proposed rule to amend Part 4043 to accommodate statutory changes made by to the Pension Protection Act of 2006, establish risk-based safe harbors that would exempt most companies and plans from reporting, and make other changes. PBGC received thirteen comments and held its first-ever regulatory hearing on the proposal. On September 11, 2015, PBGC published a final rule that changes the reportable events regulation.

Each event is listed below. For more information about an event, click on the cited regulation. In certain cases involving nonpublic companies with large underfunding (see 29 CFR §4043.61), advance notice of certain events must be given to PBGC.

Reportable Event

Post-Event Notice
(Form 10)

Advance Notice (Form 10-Advance)

Active participant reduction

29 CFR §4043.23


Failure to make required funding payments

29 CFR §4043.25


Inability to pay benefits when due

29 CFR §4043.26


Distribution to a substantial owner

29 CFR §4043.27


Change in contributing sponsor or controlled group

29 CFR §4043.29

29 CFR §4043.62

Liquidation of contributing sponsor or controlled group member

29 CFR §4043.30

29 CFR §4043.63

Extraordinary dividend or stock redemption

29 CFR §4043.31

29 CFR §4043.64

Transfer of benefit liabilities

29 CFR §4043.32

29 CFR §4043.65

Application for minimum funding waiver

29 CFR §4043.33

29 CFR §4043.66

Loan default

29 CFR §4043.34

29 CFR §4043.67

Bankruptcy or similar settlement

29 CFR §4043.35

29 CFR §4043.68

Large Cumulative Funding Underpayments

10 days after the due date (Form 200)

Total underpayments, with interest, exceed $1 million

29 CFR §4043.81

Filing Requirements

The forms and instructions provided below explain which events must be reported to PBGC, when they must be reported, what information PBGC requires, and where and how to file the report.

Post-Event Notice of Reportable Events

Advance Notice of Reportable Events

Notice of Failure to Make Required Contributions Over $1 Million

Technical Updates on 4043 Reporting

Enrolled Actuaries Meeting Bluebooks - 4043 reporting

In connection with Enrolled Actuaries Meetings, PBGC staff has met with representatives of the Enrolled Actuaries Program Committee to discuss a number of questions relating to these reporting requirements. Summaries of the questions and answers (in PDF format) discussed at the meetings are available here as a public service.

The summaries reflect the views of individual staff members and do not represent the official position of PBGC.

2015 Question & Answer Summary (Questions 12-15) [PDF]
2012 Question & Answer Summary (Questions 15-16) [PDF]
2011 Question & Answer Summary (Question 13) [PDF]
2010 Question & Answer Summary (Questions 17-20, 31) [PDF]
2009 Question & Answer Summary (Questions 17-19) [PDF]
2008 Question & Answer Summary (Question 9) [PDF]
2007 Question & Answer Summary (Questions 3, 14-16) [PDF]
2006 Question & Answer Summary (Questions 12-15) [PDF]
2005 Question & Answer Summary (Question 17-19) [PDF]
2004 Question & Answer Summary (Question 11-13) [PDF]
2001 Question & Answer Summary (Question 15-16) [PDF]
2000 Question & Answer Summary (Question 19-20) [PDF]
1998 Question & Answer Summary (Question 20-34) [PDF]

Filing Assistance

For assistance, contact PBGC by sending an e-mail to,, or (whichever applicable), or by calling our toll-free practitioner number at 1-800-736-2444 (ext. 4070) or 202-326-4070 (DC area). TTY/ASCII users may call the federal relay service toll-free at 1-800-877-8339 and ask to be connected to the appropriate number.


PBGC regularly monitors plan compliance with Part 4043 using, among other methods:

  • electronic data comparison of information reported on PBGC premium and Form 5500 filings;
  • financial information services and news databases; and
  • information sharing with the Department of Labor, the Internal Revenue Service, and the Securities and Exchange Commission.


PBGC's current penalty policy applies to failure to timely file information required by Part 4043. See also ERISA section 4071 and 29 CFR Part 4071.

Reportable Events FAQs

On September 11, 2015, PBGC announced new final rules for reportable events, focusing on the minority of plans and sponsors that pose the greatest risk of defaulting on their financial obligations. For more information on the final rule see our Reportable Events FAQs.