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Software Developer E-filing Resources for Integrating with PBGC

Software Developer E-filing Resources for Integrating with PBGC

Introduction

PBGC's premium e-filing application, My Plan Administration Account (My PAA) supports XML specifications that allow properly formatted filing data from an external source to be submitted to PBGC via My PAA. The information on this page is intended for private-sector software vendors/developers who wish to update their software to support premium e-filing using these XML specifications.

Overview

PBGC Premium E-Filing Data Standards

Vendor/Developer Resources

Contact us

If you are a software vendor/developer and have questions or comments about how to modify your product to integrate with PBGC's requirements, please send them to the PBGC e-filing team at: softwareefiling@pbgc.gov

Overview

How Practitioners submit Software-Prepared E-Filings to PBGC

My PAA allows pension plan practitioners to submit premium filing information via data files that adhere to an XML specification published by PBGC in one of two ways - Import and Upload:

  • Import: A filer imports an XML file containing filing information for a plan in their account for plan years 2008 and later. Filers then use My PAA's features to review, edit, sign, and submit each filing to PBGC. Each user who works on the filing must have an account in My PAA.
  • Upload: A filer uploads, certifies, and submits an XML file containing complete filing information for up to approximately 100 filings, for plan years 2008 and later. Only the user uploading the file is required to have an account in My PAA; however, filers do not have the opportunity to make changes to the filing information in My PAA using this method.
     

For more information about these premium filing options from the user's perspective, review the Premium E-Filing Options found under the Practitioners Tab, Online Premium Filing section.

How Software Vendors/Developers Submit Draft Premium XML Files to PBGC for Review and Verification

PBGC has established a review and verification process (outlined in three steps below) for private-sector software vendors/developers to follow. The purpose of this process is to ensure that the premium XML files produced by this software adhere to the PBGC defined standards and it requires vendors/developers to submit XML files that contain filing information for a variety of filing scenarios. Note that XML files must typically be submitted to PBGC when there are changes to the schema. If the schema does not change, vendors/developers are still encouraged to validate their own sample files for the new plan year.

If the submitted XML files do not meet the standards, PBGC will provide vendors/developers with the resulting error messages and will provide any necessary assistance. If the XML files submitted by a software vendor/developer meet the standards, PBGC will assign a unique vendor identification number that must be included in all XML files created by a vendor's/developer's software.

Note: The assignment of this number simply means that the sample XML files submitted met the PBGC-defined standards. It does not mean that all XML files produced by a software product will be valid. For this reason, we strongly recommend that vendors/developers produce a wide variety of premium filing XML files and test them using the Schema Validation Service. See Sample PBGC Premium Filings in XML Format for more information about the types of filings premium filing software should be able to produce.

To receive a vendor identification number that is valid for submission of Comprehensive Filings (for plan years starting 2020), the following types of filings must be submitted to PBGC for verification:

The following note applies to all 7 Test Files below:  Optional elements under Risk Transfer node ‘LSOfferedParticipantsInPay’ and ‘LSElectedParticipantsInPay’ are applicable to 2015 Filings as well as 2020 and Later Filings. Also, the ‘PlanAdminSignDate’ is now an optional element for 2020 and Later Filings.

Test File 1 - 2020 Comprehensive filing for a Single-employer Plan with all Risk Transfer Questions
 

Test File 2 - 2020 Comprehensive filing for a Single-employer plan with partial Risk Transfer Questions, form fields 18a(1)(i), 18a(1)(ii), 18a(2)(i), and 18a(2)(ii)
 

Test File 3 - 2020 Comprehensive filing for a Single-employer plan, with partial Risk Transfer Questions, form fields 18a(2)(i) and 18a(2)(ii)
 

Test File 4 - 2020 Comprehensive filing for Single-employer Plan, with partial Risk Transfer Questions, form fields 18a(2)(i), 18a(2)(ii), 18b(1), and 18b(2)
 

Test File 5 - 2020 Comprehensive filing for Multi-employer Plan, with all Risk Transfer Questions
 

Test File 6 - 2020 Comprehensive filing for Multi-employer Plan, with partial Risk Transfer Questions, form fields 18a(2)(i) and 18a(2)(ii)
 

Test File 7 - 2020 Comprehensive filing for a Single-employer Plan, with no PA Sign Date

After you have validated the above seven scenarios, forward the XMLs for all of the filings described in the specific Test Files to PBGC for review (via softwareefiling@pbgc.gov), and include the following information so that each test file is clearly identified and we can call or email you if there are questions:

  • Test file names should be descriptive and start with the requested test file number that matches the scenario described.
     
  • Your name, your company name, and your contact information (telephone number and email address).

If your software will also be used to submit Comprehensive Filings for plan year 2019 and PBGC has not previously reviewed your filings, the following types of filings must be submitted to PBGC for verification:

Test File 1 - 2019 Comprehensive filing for a Single-employer Plan

  • Note: Optional Element ‘CessationEnterExplanation’. This element is applicable to 2019 and Later Filings, if the cessation of coverage box is selected

 

Test File 2 - 2019 Comprehensive filing for a Single-employer plan, claiming disaster relief and plan administrator address is different that than the disaster area address

  • Note: Include the node ‘No’, with address elements, if the plan administrator’s address is different than the disaster area covered by the applicable IRS News Release

Test File 3 - 2019 Comprehensive filing for a Single-employer plan, claiming disaster relief and plan administrator address is same as the disaster area address

 

Test File 4 - 2019 Comprehensive filing for a Multi-employer Plan

  • Note: Optional Element ‘CessationEnterExplanation’. This element is applicable to 2019 and Later Filings, if the cessation of coverage box is selected

 

Test File 5 - 2019 Comprehensive filing for a Multi-employer plan, claiming disaster relief and plan administrator address is different that than the disaster area address

  • Note: Include the node ‘No’, with address elements, if the plan administrator’s address is different than the disaster area covered by the applicable IRS News Release

 

Test File 6 - 2019 Comprehensive filing for a Multi-employer plan, claiming disaster relief and plan administrator address is same as the disaster area address

If your software will also be used to submit Comprehensive Filings for plan year 2015 through 2018 and PBGC has not previously reviewed your filings, the following types of filings must be submitted to PBGC for verification:

Test File 1 – 2015 Comprehensive filing for Single-employer plan, exempt from VRP, Risk Transfer, Alternative Phone Number, APFT Revocation, Certification of Plan Administrator
 

Test File 2 – 2015 Comprehensive filing for a Single-employer plan, small plan, VRP, Alternative Phone Number, Certification of Plan Administrator and Actuary
 

Test File 3 – 2015 Comprehensive filing for Multi-employer plan, small plan, Risk Transfer, Alternative Phone Number, Certification of Plan Administrator


Test File 4 – 2015 Comprehensive filing for Single-employer plan, small plan, Reporting Unfunded Vested Benefits, Certification of Plan Administrator and Actuary


Test File 5 – 2016 Comprehensive filing for Single-employer plan, exempt from VRP, with partial Risk Transfer questions, form fields 18b(1) and 18b(2)


Test File 6 – 2016 Multi-employer, small plan, Risk Transfer, Alternative Phone Number, Certification of Plan Administrator


Test File 7 – 2017 Comprehensive filing for Multi-employer plan with all Risk Transfer questions


Test File 8 – 2017 Comprehensive filing for a Single-employer plan, non-exempt from VRP, with all Risk Transfer questions

If your software will also be used to submit Comprehensive Filings for plan years 2008 through 2014 and PBGC has not previously reviewed your filings, the following types of filings must be submitted to PBGC for verification:

Test File 1 – Comprehensive filing for a Single-employer plan exempt from VRP


Test File 2 – Comprehensive filing for a Single-employer medium or large plan not exempt from VRP


Test File 3 – Comprehensive filing for a Single-employer small plan that qualifies for the VRP cap and is only paying the VRP cap (i.e., is not reporting the Unfunded Vested Benefit amount)


Test File 4 – Comprehensive filing for a Single-employer plan eligible for the cap on the VRP and elects to provide the Unfunded Vested Benefit amount to pay the lesser of the VRP based on Unfunded Vested Benefit amount calculation or the VRP cap


Test File 5 – Comprehensive filing for a Multi-employer plan


Test file 6 – Comprehensive filing for which premium proration applies for both a Single-employer and Multi-employer plan

Below are the three steps for software vendors/developers to follow to send test premium filing XML files to PBGC for review:

Step 1: Test your XML files yourself using our Vendor Validator Web Service, (see Testing XML files / Submission Validation Service (SVS)); and then submit them to PBGC for review. When you are ready, send an email to softwareefiling@pbgc.gov with the following information:

  • Company name
  • Product name
  • Product version and/or release number
  • Your first name and last name
  • Business telephone number
  • Business email address
  • A description of the XML file that you are submitting for review that contains the plan year and type of filing (e.g., 2008 Final Filing, 2012 Comprehensive Filing).
  • Attach the XML files that you are asking PBGC to review

Step 2: PBGC will acknowledge receipt of submitted XML file(s) and will verify each submission, for example, that:

  • The XML is properly formatted
  • Each sample file meets the approved XML schema
  • Each file has all the required data based on the type of filing information included in that file. 

Step 3: PBGC will respond with XML file review results such as:

  • If your submissions contained errors, the response will identify the files that caused the error and provide detailed error messages.
  • If your sample files were approved, PBGC will provide you with a unique vendor identification number to insert into your final XML documents using the Provider Approval Number field. This would be a static data element and should be present in every premium filing XML submission. Note that a new vendor identification number is typically assigned when new sample files are submitted/approved as the result of a schema change.

Vendor Listing

To date, the following private-sector software vendors/developers have supplied PBGC with sample electronic premium filings that meet PBGC's current technical requirements for an XML file for the plan years shown below. As a result, PBGC has assigned each of these vendors a vendor identification number:

  • ASC Corporation (2009 to 2020)
  • BLAZE SSI Corp. (2008 to 2020)
  • DATAIR Employee Benefit Systems, Inc. (2008 to 2020)
  • Ftwilliam.com (2008 to 2020)
  • Principal Financial Group (2008 to 2020)
  • FIS - Relius Government Forms (2008 to 2020)

PBGC Premium E-Filing Data Standards

Premium e-filing XML Specifications

These data standards are applicable to premium filings starting with the 2008 plan year. A premium filing submitted to PBGC via My PAA in XML format must adhere to the premium filing XML schema published by PBGC.

A filing is composed of three core schema files (Effective 01/24/2020):

Submission: This primary schema defines a complete and valid premium filing. All premium filing XML files will be validated against this document. Download submission.xsd

Submission Types: This documents the data type definitions used throughout the schema definitions. Download submission-types.xsd

Premium Filing: This schema document explains the element and format definitions for 2008 and later comprehensive filing data. Download premium-filing.xsd
 

Mapping filing questions to the latest schema

To review additional details regarding how elements in the schemas map to data elements as identified by PBGC's forms and instructions, review the following PDF files:

2020 and later Comprehensive Filings [PDF]

2019 Comprehensive Filings [PDF]

2016-2018 Comprehensive Filings [PDF]

2015 Comprehensive Filings [PDF]       

2014 Comprehensive Filings [PDF]

2013 Comprehensive and Estimated Filings [PDF]

2008 – 2012 Comprehensive Filings[PDF]
 

Vendor/Developer Resources

Sample PBGC Premium Filings in XML Format

XML Samples for 2020 and later Comprenhensive Filings

To view the XML examples, open this zip file: 2020-XML-samples.zip

Reference the PDF file titled 2020-Samples-Description-Mapping.pdf for information about each filing scenario and the data used in each XML sample for Comprehensive Filings starting 2020 and above. Please note that the 2020 XML Samples includes examples with existing schema elements as follows: "LSOfferedParticipantsNotInPay" for Form field 18a(1)(i), element "LSElectedParticipantsNotInPay" for Form field 18a(1)(ii), re-use of element "LSOfferedParticipantsInPay" for Form field 18a(2)(i), and re-use of element "LSElectedParticipantsInPay" for Form field 18a(2)(ii). 

Note that the last two elements were ignored by My PAA system for plan years 2016-2019 and were not used for filings.

XML Samples for 2019 Comprehensive Filings

To view the XML examples, open this zip file: 2019_XML_Samples.zip

Reference the PDF file titled 2019-Samples-Description-Mapping.pdf for information about each filing scenario and the data used in each XML sample for Comprehensive Filings starting 2019 and above. Please note that the 2019 XML Samples includes examples with correct use of the following new schema elements/nodes: ‘CessationEnterExplanation’; ‘DisasterReliefANN’.

XML Samples for 2016 to 2018 Comprehensive Filings

To view the XML examples, open this zip file: 2016-2018 XML Samples.zip

Reference the PDF file titled 2016-2018-Samples-Description-Mapping.pdf for information about each filing scenario and the data used in each XML sample for Comprehensive Filings starting 2016 and above. Please note that the 2016-2018 XML Samples include examples with correct use of existing schema element "LSOfferedParticipantsNotInPay" for Form field 18a(1) and element "LSElectedParticipantsNotInPay" for Form field 18a(2). Note that in the XML schema, there are two existing elements "LSOfferedParticipantsInPay" and "LSElectedParticipantsInPay" that will be ignored by My PAA system and, therefore, should not be used for filings for plan years starting 2016.

XML Samples for 2015 Comprehensive Filings

To view the XML examples, open this zip file: 2015-XML-Samples.zip

Reference the PDF file titled 2015-Samples-Description-Mapping.pdf for information about each filing scenario and the data used in each XML sample for Comprehensive Filings starting 2015. Please note that the 2015 XML Samples zip file also includes a 2014 single-employer test file that reflects a small cap, not exempt from VRP, no UVB scenario. The updated schema also includes two new optional nodes for 2015 filings, one for the "Plan Administrator Certification" (PlanAdminCertificationExt) and another for the "Enrolled Actuary Certification" (ActuaryInformationExt). The new nodes must be used for the 2015 filings and on-wards; while the old nodes can be used for 2014 and prior filings.

XML Samples for 2014 Comprehensive Filings

To view the XML examples, open this zip file: 2014-XML-Samples.zip

Reference the PDF file titled 2014-Samples-Description-Mapping.pdf for information about each filing scenario and the data used in each XML sample for Comprehensive Filings starting 2014. Please note that the 2014 XML Samples zip file also includes a 2013 single-employer test file that reflects a small cap, not exempt from VRP, no UVB scenario. The new data fields starting plan year 2014 (i.e., IsSmallPlan, ParticipantCountFields node that includes ParticipantCountActive, ParticipantCountTerminatedVested, and ParticipantCountRetireesandBeneficiaries) DO NOT apply to any 2013 or earlier filings. You should notice that the 2013 sample does not use any new 2014 elements.

XML Samples for 2013 Comprehensive and Estimated Filings

To view the XML examples, open this zip file: 2013_ XML_Samples.zip

Reference the PDF file titled 2013_Samples_Description_Mapping.pdf for information about each filing scenario and the data used in each XML sample for Comprehensive and Estimated Filings starting 2013.

XML Samples for 2008 – 2012 Comprehensive Filings

The Sample XML files provided cover the filing scenarios for which each vendor/developer must submit test files to PBGC for 2008 – 2012 Comprehensive Filings. In addition to meeting the minimum requirements for submitting test filings to PBGC, the sample files provided here illustrate use of many of the elements new to the schema beginning in 2008.

To view the XML examples, open this zip file: Comprehensive_Filing_XML_filing_samples.zip.

Reference the PDF file titled 2008ComprehensiveDataMappingforSamples.pdf for information about each filing scenario and the data used in each XML sample.

Testing XML files / Submission Validation Service (SVS)

PBGC has developed the Submission Validation Service (SVS) which validates XML files against PBGC's specifications. A technical description of the SVS is provided in PDF format. Developers may access this service via a web-based Validation utility to ensure that the XML files generated by their software are properly structured for submission to PBGC. Use this validation service to test XML files that contain test filing data (for plan years starting 2008). The SVS was last updated Jan. 2020 to validate against the new schema.

The service will provide an immediate success/failure response for each XML file you test. If an XML file passes, SVS provides a message that lets you know this file has passed. If an XML file fails, SVS will provide detailed error messages, such as the example below.

Example failure notice

Error Message: The 'http://www.pbgc.gov/plan_admin/efiling/Submission:PlanYearEndDate' element has an invalid value according to its data type.

Problem: The filing has an improperly formatted date element

Download technical description of SVS [PDF]
Go to Validation Utility

Form Codes

Mapping of the Form Code is unique by form type/year. You should provide the Form Code appropriate to the form type/year of the filing being submitted in the FormCode element within PremiumFiling.XSD. 

Form Code Table

Year Form code
2020 675129
2019 573126
2018 456732
2017 364578
2016 271843
2015 154328
2014 921857
2013 863215
2012 742639
2011 634295
2010 564718
2009 432571
2008 325784

 

Tips for Creating PBGC Premium Filings in XML Format

Please refer to the schema documents to identify all schema rules and validations (including rules governing field type and length). Following are tips and additional requirements not explicit in the schema documents that vendors/developers must follow when modifying their software to create premium filings in XML format. The information below is provided based on specific questions and issues that have been encountered by developers in generating XML files that meet the PBGC specification:

Additional Checks PBGC Does on Submitted Premium Filings

When a premium filing passes the schema and is submitted, PBGC checks the accuracy and validity of the information reported. If any filing data does not pass the business rules validations, the filer will be contacted and may need to submit an amended filing with corrected information. To help improve filing accuracy, we suggest the following:

  • At the root level, the document defines PlanData and FilingData.
  • Within PlanData, the date provided in PlanYearBeginDate identifies the plan year commencement date
  • The FilingData element must contain FinalFilingData. Within FinalFilingData, the FilingPlanType element must contain either the MultiEmployer element or SingleEmployer element; this defines the plan type for a final or comprehensive filing.
  • Additional key elements define the filing further as described below:

A Comprehensive Filing (starting plan year 2008) is defined by the presence of a Plan Year Commencement date in PlanData, PlanYearBeginDate which includes 2008 or later as the year, and the presence of the FilingData\FinalFilingData element.

My PAA will reject an XML file that has the nodes in the incorrect order. An XML file must provide the data in the specified order according to the schema. The schema enforces this rule to better enable PBGC to review and verify your sample filings. In addition, a consistent ordering of schema data elements assists with manual filing review.

Use IsSmall Plan (YES or NO) for 2014 and later only. The existing element Plan Size (SmallPlanSize or MidSizePlanSize or LargePlanSize or PlanSizeNAFirstYearsFiling) is used for 2008 to 2013 years only.

Use ParticipantCountFields node for 2014 and later only. If you include the node you must have all three elements ParticipantCountActive, ParticipantCountTerminatedVested, and ParticipantCountRetireesandBeneficiaries under the node. You cannot have an empty ParticipantCountFields node.

Do not include commas in any value in a numeric XML node.

Do not submit an XML premium filing to the PBGC with empty XML nodes.

My PAA will reject an XML file that has empty nodes, regardless if the nodes are mandatory or optional (the only exception to this is if the node type is "string" with no restriction for minimum length.) For example: Submitting an XML file with an empty Amended Filling node would look like this - and will generate the following error when validating the XML filing:

The http://www.pbgc.gov/plan_admin/efiling/Filing:AmendedFiling element has an invalid value according to its data type. An error occurred at , (1, 1814).

The correct way to show that a filing is not an amended filing is to submit the XML file without the node since this is an optional node.

Be sure to use the accurate spelling of all XML nodes. In addition, the XML node names are case sensitive.

My PAA will reject an XML file with misspelled XML node names or with node names those that do not match the case as indicated in the schema documents.

Be sure to include correct namespace (xmlns) references to the submission, submissiontypes, and premiumfiling in your XML premium filing documents. For example, if the following namespace is used:

xmlns:f="http://www.pbgc.gov/plan_admin/efiling/PremiumFiling" xmlns:st="http://www.pbgc.gov/plan_admin/efiling/SubmissionTypes"
The tag names of XML elements should have prefixes in reference to these namespaces. Schema validation will generate an error if any of these prefixes are omitted from the XML document. For example, in the XML, "st" is the namespace prefix for Submission Types and "f" for PremiumFiling.
Submitting XMLs without the "st" tag prefix may cause the following validation errors:

  1. The element 'http://www.pbgc.gov/plan_admin/efiling/Filing:SingleEmployerPremium' has invalid child element 'http://www.pbgc.gov/plan_admin/efiling/Submission:FlatRatePremium'. Expected 'http://www.pbgc.gov/plan_admin/efiling/SubmissionTypes:FlatRatePremium'. An error occurred at, (1, 2222).
  2. The 'http://www.pbgc.gov/plan_admin/efiling/Submission:FlatRatePremium' element is not declared. An error occurred at, (1, 2222).
  3. The 'http://www.pbgc.gov/plan_admin/efiling/Submission:TotalPremium' element is not declared. An error occurred at, (1, 2316).
     

Including multiple filings in one XML submission
PBGC developed the requirements for XML files so that multiple filings (approximately 100) can be included in one XML file in anticipation of scenarios like the following:

There is no restriction on combining different types of filings or different plan years within a single XML submission. The XML structure dictates that each filing be saved in the XML in an "envelope" - each filing would begin with the opening tag and each will end with the closing tag. One XML file may contain multiple envelopes.

It is important to note how My PAA handles an XML file that contains multiple filings for the same plan (identified by EIN/PN), depending on how the user chooses to submit the XML - either by uploading it or importing it. For example:

Third party administrators who create filings for different plans for their customers or for a sponsor who has several plans and would like to put them all in one XML file that can be imported or uploaded to My PAA at one time.

Plans that may have to submit a filing for two different plan years - e.g., the plan might need to submit an amended filing for the 2008 plan year and a new filing for the 2013 plan year.

Values for "Yes" and "No" nodes

There are numerous elements within the schemas that map to checkbox items on the paper forms. In the XML, these items are represented within a parent sub-element. In some cases, depending on which node is present (Yes or No) an additional element is required, such as with Disaster Relief where a Yes node requires the Disaster Relief Explanation node. When there is not a dependent element in the selected node, a value of 'X' should be provided for the element.

Country Codes List (Effective 12/18/2013)

Effective December 18, 2013, all filings with a foreign address must use the ISO Standard 3166-1 alpha-2 country code in the "Country" node. The acceptable country codes are shown on the ISO Country Codes List.

Small Employer Cap

For 2008 and later, if the plan has indicated that they qualify for the cap, this element may be included but is not required. If included, it should be equal to the value of Unfunded Vested Benefits (item 7f) * VRPCap. For 2013+: this element should be included when claiming the small employer cap and reporting Unfunded Vested Benefits.

Review each year's premium payment instructions for information about changes that may impact the accuracy of filings. For example, the premium instructions starting 2013 state that only dollars should be reported for the Premium Funding Target data elements which include active participants, terminated vested participants, retirees and beneficiaries receiving payment, and the total premium funding target.

Review the My PAA FAQs on our website, particularly "How can I help ensure that my premium filing is accurate and complete?" The FAQ provides filing reminders such as reporting the name and contact information of the plan administrator and actuary who have certified or will certify the filing in the certification section of each uploaded filing (within the XML filing data).

Last updated January 16, 2021