IRS Gathers Feedback After Digital Filing Mandate for Multiemployer Plans Sparks Confusion

WASHINGTON — The U.S. Department of the Treasury and the Internal Revenue Service are fielding feedback from plan administrators and actuaries following the mandatory transition to a fully digital submission process this year for a key multiemployer pension plan form. The change, which affects the annual filing of Form 15315, “Actuarial Certification for Multiemployer Defined Benefit Plans,” generated a significant number of inquiries, according to a Treasury official. Speaking at the American Bar Association Section of Taxation 2026 May Tax Meeting, Scott Steadman, an attorney in the Treasury’s Office of Tax Policy, acknowledged the transition prompted “a lot of phone calls to me about what was happening.” Form 15315 is a critical annual filing submitted by a multiemployer plan’s actuary. It certifies the plan's financial health and determines whether it is, or is projected to be, in “endangered” or “critical” status under the guidelines of the Pension Protection Act of 2006. This certification is a fundamental component of the regulatory framework designed to ensure the long-term solvency of pension plans that cover millions of workers across various industries. A plan’s designation as endangered or critical triggers legal requirements for the plan sponsors to adopt either a funding improvement plan or a rehabilitation plan. These plans impose stricter funding schedules and sometimes require benefit adjustments to steer the plan back toward financial stability. The accuracy and timeliness of the Form 15315 filing are therefore paramount for both regulatory compliance and the financial security of plan participants. Multiemployer plans are distinct from single-employer plans or multiple employer plans (MEPs). They are collectively bargained pension plans maintained by two or more unrelated employers, typically within the same or related industries, and a labor union. The shift to a mandatory digital submission for their annual certification represents a significant operational change for the actuaries and third-party administrators who handle these complex filings. This move is part of a broader, agency-wide initiative by the IRS to modernize its processes and phase out paper-based submissions in favor of more efficient electronic systems. The agency has been rolling out similar mandates for other forms. For instance, beginning September 1, 2024, applications for approval of pre-approved defined benefit and defined contribution plans, such as Forms 4461-A and 4461-C, must be submitted electronically through the Pay.gov portal. The IRS has stated that paper submissions for these forms postmarked after August 31, 2024, will no longer be processed. While the goal of digitization is to improve processing speed, reduce errors, and create a more robust data repository for the agency, the initial rollout of such changes can create significant logistical challenges for filers. The feedback and calls noted by Steadman suggest that plan professionals encountered issues ranging from technical glitches with the new portal to confusion about the specific requirements of the digital format. For organizations accustomed to decades-old paper-based workflows, the transition requires new training, updated internal processes, and potentially new software. The stakes for small and mid-sized businesses that contribute to these multiemployer plans are substantial. While they may not be directly involved in filing Form 15315, the outcome of the certification directly impacts their required contribution levels. A designation of critical or endangered status can lead to increased funding obligations, which can place significant financial pressure on participating employers. In our experience, the IRS's push toward mandatory electronic filing, while beneficial in the long run, consistently creates short-term operational hurdles for businesses and plan administrators. This transition for Form 15315 is a perfect example of a seemingly minor procedural update that can cause significant disruption if not managed proactively. The phone calls the Treasury received underscore the reality that compliance is not just about knowing the rules but also about mastering the mechanics of the filing systems. For businesses involved in complex benefit plans, overlooking these procedural shifts can lead to filing errors, delays, and unnecessary regulatory scrutiny. This is precisely where expert guidance on tax preparation and compliance becomes invaluable. The team at C&S Finance Group LLC helps clients navigate these evolving IRS requirements to ensure filings are accurate and timely. To learn how we can assist your business, visit us at csfinancegroup.com. The Treasury and the IRS have not yet announced specific changes based on the feedback from this year's filing season. However, the information gathered will likely be used to refine the digital submission system, clarify instructions, and improve the user experience for actuaries and plan administrators in the future. Plan professionals and participating employers should monitor official IRS communications for any updates to the process ahead of the next filing cycle.