On February 26, 2021, the DOL issued guidance regarding the impact of that statutory limitation on the previously announced deadline extensions, in EBSA Disaster Relief Notice 2021-01.

Disaster Relief Notice 2021-01, in essence, provides that the one-year statutory limitation on the Agencies’ ability to extend deadlines should be applied separately for each participant and each event triggering a deadline that is subject to extension under the April 28, 2020 guidance, rather than to all events taken together with a single end date for applicable deadline extensions.