DOL Updates Civil Monetary Penalties for 2025

The Department of Labor has announced updated penalty amounts for violations assessed a penalty after January 15, 2025.  Below is a table of some of the civil monetary penalties relevant to employee benefit plans.  The DOL can waive penalties or assess lower penalties than these when they determine the employer has acted in good faith to promptly identify and correct errors it discovers. 

Requirement	2024 Penalty	2025 Penalty
Filing Form 5500	$2,670 per day it’s late	$2,739 per day it’s late
Furnishing SBCs	$1,406 per failure	$1,443 per failure
GINA violations	$141 per person per day	$145 per person per day
Medicaid/CHIP notice	$141 per person per day	$145 per person per day
MEWA M-1 Filing	$1,942 per day it’s late	$1,992 per day it’s late

IMA will continue to monitor regulator guidance and offer meaningful, practical, timely information. This material should not be considered as a substitute for legal, tax and/or actuarial advice. Contact the appropriate professional counsel for such matters. These materials are not exhaustive and are subject to possible changes in applicable laws, rules, and regulations and their interpretations.

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