On January 27, 2026, the Pension Benefit Guaranty Corporation (PBGC) released two reports:

• The Fiscal Year (FY) 2025 Annual Report reviews the operations and finances of the PBGC’s insurance programs for single-employer and multiemployer defined benefit (DB) plans for the fiscal year (FY) ending September 30, 2025.
• The Fiscal Year (FY) 2024 Projections Report forecasts the financial condition of the PBGC’s single-employer program through FY 2034 (September 30, 2034), and multiemployer insurance program through FY 2034 and through FY 2064.

Below is a summary of the key findings from these reports.

The net financial position of the single-employer insurance program is projected to increase significantly over the next 10 years

The single-employer insurance program’s net financial position grew to $62.2 billion as of September 30, 2025, up from $54.2 billion as of September 30, 2024. Premiums for the fiscal year were $4.1 billion.

Projections. The FY 2024 Projections Report noted that the net financial position of the program over the next 10 years is expected to remain positive in all 5,000 scenarios, due to premium income and earnings on surplus assets exceeding projected benefit claims. The net financial position is projected to grow to a median (50th percentile¹) funded position of $104.8 billion by FY 2034. The program’s projected net financial position in 10 years ranges from $93.2 billion at the 15th percentile to $117.3 billion at the 85th percentile.

The report also noted that even under an extreme stress test scenario—combining a significant market downturn (20% reduction in the median asset return in the first year of the projection without a subsequent recovery) with new claims comparable to the high level of claims experienced from 2001–2006 (economically adjusted), amounting to approximately $32 billion projected for FY 2025–2030—the net financial position remains positive and grows over the 10-year projection period.

Notable activities during the 2025 FY. The FY 2025 Annual Report highlighted the following items:

• PBGC paid $6.4 billion in benefits to about 926,000 participants. In addition, 31 plans were trusteed during FY 2025, covering about 20,000 participants.
• There were 2,264 plans covering about 341,000 participants that filed standard terminations with the PBGC, which was 27% more than the average number of filings received over the previous five years. 2,103 plans filed for standard terminations in FY 2024.
• There were 2,121 plans covering more than 313,000 participants that completed standard terminations in FY 2025 by settling plan obligations through annuities or lump sums. 1,778 plans completed standard terminations in FY 2024.
• The PBGC completed 270 standard termination audits in FY 2025, which resulted in $3.1 million in additional benefits being paid to 581 individuals in these plans.

The single-employer insurance program covers about 18.4 million participants in about 22,200 DB plans.

The net financial position of the multiemployer insurance program is likely to remain positive for more than 40 years

The multiemployer insurance program’s net financial position reached $2.6 billion as of September 30, 2025, up from $2.1 billion as of September 30, 2024. Premiums for FY 2025 were $426 million.

Projections. In the 500 stochastic projection scenarios conducted for the report, 67% indicated the program will remain solvent for more than 40 years, up from 61% of scenarios run last year. The report notes the high degree of uncertainty in these projections, with the most pessimistic scenarios showing the program becoming insolvent as early as 2039 (later than the 2037 date projected last year) and the optimistic scenarios showing the program remaining solvent indefinitely. How long the insurance program remains solvent depends on how investments perform in the future, the amount of contribution income received, and the future levels of benefit payments for covered plans.

The median (50th percentile²) projected net financial position of the program in 10 years is $7.4 billion, up from $4.4 billion last year, with a 75% probability of a positive net position at the end of FY 2034. The program’s projected net financial position in 10 years ranges from a shortfall of $6.2 billion at the 15th percentile to a positive $9.0 billion at the 85th percentile, both improvements from last year’s report.

The biggest contributor to the program’s recent financial recovery is the special financial assistance (SFA) program established under the American Rescue Plan of 2021 (ARP). Prior to the enactment of ARP, the PBGC multiemployer insurance program was expected to go insolvent by 2026. The SFA program provides a one-time cash payment to qualifying financially distressed plans to pay for projected benefit payments and expenses through the plan year ending in 2051, calculated using specified assumptions.³ The program is funded through transfers from the U.S. Treasury Department, rather than from the PBGC multiemployer insurance program. In the projections report, the PBGC estimates the program will pay about $79.1 billion in SFA. Through FY 2025, PBGC has approved $74.1 billion in SFA for 174 plans.

Notable activities and events during the 2025 FY. The FY 2025 Annual Report highlighted the following items:

• A total of $168.5 million in traditional financial assistance was paid to 100 plans covering 60,244 participants.
• PBGC approved 47 SFA applications and distributed $6.2 billion in SFA during the fiscal year. In addition, PBGC completed the review of the census data for 64 plans that received SFA in the program’s earliest days by comparing the data to the Social Security Administration’s full death master file. This allowed PBGC to identify any deaths not previously captured in the census data and to recalculate SFA. Four plans did not need any adjustment to their SFA. The SFA for the other 60 plans was recalculated, and overages totaling $119.5 million were repaid.
• The report noted two significant litigation matters. The first is an ongoing legal matter relating to the denial of the SFA application for the Bakery Drivers Local 550 and Industry Pension Fund. The plan terminated by mass withdrawal in 2016 and the PBGC determined the plan was not eligible for SFA. The plan challenged in court, and the court ruled in favor of the PBGC. The plan appealed to the Second Circuit Court of Appeals, which ruled in favor of the plan. In December 2025, the PBGC filed a petition with the Supreme Court to review the appellate court decision.
• The second case involves the Yellow Corporation, which challenged the phase-in of SFA for withdrawal liability purposes. The case advanced to the Third Circuit Court of Appeals, which ruled the American Rescue Plan Act gave PBGC the authority to issue the SFA regulations and that the rules are reasonable.
• The PBGC approved two requests to adopt an alternative method for allocating unfunded vested benefit (UVB) liability in determining withdrawal liability. Three additional requests are pending.
• The agency received 11 notices of plan mergers during FY 2025.

The multiemployer insurance program covers about 11.1 million participants in about 1,300 DB plans.

Please contact your Milliman consultant with any questions.

¹ Percentiles indicate the number of projection results below the stated amount. For example, the 15th percentile means that 15% of model results are below the stated amount and 85% of model results are above the amount.

² Ibid.

³ Some plans received a supplemented SFA amount due to changes made to the calculation of SFA between the PBGC interim final rule and the final rule.