IRS Form 15315 – IRS Forms, Instructions, Pubs 2026 – In the complex world of retirement planning, multiemployer defined benefit plans play a crucial role in providing secure pensions for workers across various industries. However, maintaining these plans requires strict compliance with IRS regulations to ensure their financial health. One essential requirement is the submission of IRS Form 15315, the Annual Certification for Multiemployer Defined Benefit Plans. This form helps certify the funding status of these plans, alerting stakeholders to potential issues like endangered or critical status. As of 2026, with ongoing updates to filing methods, understanding this form is vital for plan actuaries, sponsors, and administrators.
This comprehensive guide covers everything you need to know about IRS Form 15315, including its purpose, filing requirements, key sections, and recent changes. Whether you’re a plan actuary preparing your annual submission or a sponsor ensuring compliance, this article will equip you with the latest information from trusted IRS sources.
What is IRS Form 15315?
IRS Form 15315 is a specialized document used to report the actuarial certification of a multiemployer defined benefit plan’s funding status under Internal Revenue Code (IRC) Section 432(b)(3). Introduced by the Pension Protection Act of 2006 (PPA), this form requires an annual assessment to determine if the plan is in endangered, seriously endangered, critical, or critical and declining status—or none of these. It also checks for projections of critical status within the next five years and verifies progress under any funding improvement or rehabilitation plans.
Multiemployer defined benefit plans, often found in industries like construction, transportation, and entertainment, pool contributions from multiple employers to provide fixed retirement benefits. The certification process ensures transparency and prompts corrective actions if funding levels fall short, protecting participants’ benefits and preventing insolvency.
The form’s latest revision, dated April 2025, reflects adjustments for inflation-adjusted penalties and streamlined digital submission options. By filing this form, actuaries help the IRS monitor plan health, which is critical for maintaining the integrity of the U.S. pension system.
Who Must File IRS Form 15315?
The responsibility for filing Form 15315 falls on the enrolled actuary of the multiemployer defined benefit plan. Plan sponsors provide necessary data, such as industry activity projections, but the actuary must sign and certify the information. This includes confirming that projections are based on reasonable actuarial assumptions and methods.
Not all retirement plans require this form—it’s specific to multiemployer defined benefit plans covered under IRC Section 432. Single-employer plans or defined contribution plans (like 401(k)s) are exempt. If your plan has received special financial assistance under ERISA Section 4262 or is subject to benefit suspensions, additional certifications may apply.
Actuaries must be enrolled with the Joint Board for the Enrollment of Actuaries and include their enrollment number on the form. Failure to involve a qualified actuary can lead to compliance issues.
When to File IRS Form 15315 and Filing Deadlines?
Timing is critical for Form 15315 submissions. The form must be filed no later than the 90th day after the start of the plan year. For example, if your plan year begins on January 1, 2026, the deadline is March 31, 2026. If the due date falls on a weekend or federal holiday, it shifts to the next business day.
Projections in the certification must use the most recent actuarial valuation data, ensuring accuracy in status determinations. Late filings are treated as failures to file an annual report under ERISA Section 502(c)(2), potentially incurring penalties of up to $1,100 per day, adjusted annually for inflation.
How to File IRS Form 15315: Step-by-Step Guide?
Filing has become more flexible in recent years. As of 2025, the IRS accepts submissions through multiple channels, making it easier for actuaries to comply. Here’s how:
- Electronic Submission (Preferred): Use the IRS’s mobile-friendly forms portal at https://www.irs.gov/mobile-friendly-forms. You’ll need an ID.me account for secure submission. This digital option, introduced recently, allows for efficient processing without attachments.
- Mail, Fax, or Email Options: For those preferring traditional methods:
- Mail: Send to the address specified in IRS guidance.
- Fax: 855-215-7122.
- Email: [email protected] with the subject line “Multiemployer Certification.”
Ensure the form is complete, including all required fields in Parts I–IV, and signed by the actuary. Multiple submissions can create duplicates, so verify receipt if needed.
Breaking Down the Key Sections of IRS Form 15315
Form 15315 is divided into four parts for clarity:
- Part I: Basic Plan Information – Includes the plan name, number, sponsor’s name, EIN, telephone, and address. Foreign addresses require full country details.
- Part II: Plan Actuary’s Information – Details the actuary’s name, firm, address, enrollment number, and contact info.
- Part III: Plan Status – The core of the form, where you check the appropriate status box (e.g., endangered, critical). Definitions include funded percentage thresholds (under 80%) and projections for funding deficiencies.
- Part IV: Scheduled Progress in Funding Improvement or Rehabilitation Plan – Certifies if the plan is meeting goals under a Funding Improvement Plan (FIP) or Rehabilitation Plan (RP), with options for Yes, No, or N/A.
The signature section affirms the accuracy of the data and adherence to actuarial standards.
Understanding Plan Status Certifications on Form 15315
The status determination is based on specific criteria:
| Status | Key Criteria |
|---|---|
| Endangered | Funded percentage < 80% or projected funding deficiency within 7 years. |
| Seriously Endangered | Endangered plus funded < 80% and funding deficiency. |
| Critical | Meets one of four IRC tests, or has received special assistance/suspensions. |
| Critical and Declining | Critical plus projected insolvency within 14–19 years. |
| Neither | Does not meet above criteria; may apply special rules. |
Projections rely on reasonable assumptions, with industry data from the sponsor. If critical status is projected within five years, sponsors can elect it early under IRC Section 432(b)(4).
Penalties for Non-Compliance with Form 15315
Non-filing or late submission can result in significant fines—up to $1,100 daily under ERISA. Additionally, inaccurate certifications may trigger audits or corrective actions, impacting plan operations. Always consult IRS guidance or a tax professional to avoid pitfalls.
Recent Updates to IRS Form 15315 in 2026
As of February 2026, the form’s April 2025 revision emphasizes digital filing via ID.me for faster processing. The IRS has expanded acceptance to include email and fax, responding to feedback from plan administrators. No major structural changes, but inflation adjustments to penalties continue. Stay updated via the IRS Employee Plans News for any announcements.
FAQs About IRS Form 15315
1. What if my plan is projected to enter critical status?
You must certify it on the form, and sponsors may elect critical status early to implement reforms.
2. Can I attach supporting documents?
No attachments are required or accepted with the form.
3. How do I get the latest version of Form 15315?
Download it from the official IRS website: https://www.irs.gov/pub/irs-pdf/f15315.pdf.
4. Is there help available for filing?
Yes, contact IRS Employee Plans Customer Account Services or visit irs.gov for resources.
For more details, refer to official IRS publications or consult a qualified expert. Proper filing of Form 15315 ensures your multiemployer plan remains compliant and sustainable in 2026 and beyond.