NQDC Open Enrollment Timeline: A Week-by-Week Q4 Checklist for Benefits Teams
An NQDC open enrollment timeline for benefits teams: the 409A deadlines, Q3 planning steps and a week-by-week Q4 checklist from launch to January payroll.
NQDC open enrollment for a calendar-year plan must wrap up by December 31, because Section 409A generally requires salary deferral elections to be made by the end of the year before the pay is earned. A workable calendar runs backward from that date: plan in Q3, give employees modeling tools in October, run the election window in November, lock elections in December and confirm payroll in January.
Provider calendars exist, but most are written for one recordkeeper's clients. This guide is a vendor-neutral, sponsor-side timeline for the 2027 plan year, with a week-by-week Q4 checklist you can adapt to your own window. The participant-facing rules are covered in 409A deferral election rules; this page focuses on what your benefits team does and when.
The 409A deadlines that set your calendar
Three rules in the Section 409A regulations drive every NQDC enrollment calendar.
| Election | Rule | Example for a calendar-year plan |
|---|---|---|
| Salary deferral for next year | Must be made by the close of the preceding taxable year | 2027 salary: elect by December 31, 2026 |
| Newly eligible participant | May elect within 30 days of becoming eligible | Eligible March 1: election window of up to 30 days |
| Performance-based bonus (performance period of at least 12 months) | May elect as late as 6 months before the period ends | Calendar-2027 performance period: elect by June 30, 2027 at the latest |
| Change to timing or form of a payment already elected | Cannot take effect for 12 months; must push payment back at least 5 years (with limited exceptions); for scheduled payments, must be made at least 12 months before the scheduled date | A payment scheduled for June 2028 must be changed by June 2027 and moved to June 2033 or later |
December 31 is the legal backstop, not a target. Your plan can set an earlier internal deadline, and building a buffer of two to three weeks gives your recordkeeper and payroll time to catch errors before elections become irrevocable. Whether a bonus qualifies as performance-based compensation is a technical question; confirm it with counsel before you advertise a mid-year bonus window.
Q3: plan the cycle (July to September)
Most of the work that makes a smooth enrollment happens before October. Use this as a planning checklist:
- Confirm the eligibility list. Apply your plan's eligibility criteria and flag anyone newly eligible. Top-hat plans must cover a "select group of management or highly compensated employees," and a DOL advisory council report notes that Congress expected that exemption to apply narrowly, so review any expansion with counsel.
- Lock plan design changes. Changes to deferral limits, employer credits, vesting, payout options or investment menus need amendments and recordkeeper lead time. See NQDC plan design best practices.
- Agree on window dates with your recordkeeper. Set the open date, the internal close date and the confirmation date.
- Plan for IRS limit updates. The 2027 limits are not yet published and are expected in November. For 2026, the 401(k) elective deferral limit is $24,500 and the compensation limit is $360,000 (IRS Notice 2025-67). If your NQDC plan offsets 401(k) refunds or restores matches above the compensation limit, those numbers feed directly into enrollment materials.
- Draft the communication plan. Map each message to a date in the Q4 table below. The NQDC enrollment communication guide has templates and sequencing ideas.
- Arrange decision support. If you want employees to have a personal modeling tool during the window, Q3 is the time to set it up. A license for NQDC Calculator for employers is configured with you: your deferral limits, payout options, employer credits and vesting become starting values, and employees sign in with their work email.
- Identify participants with upcoming scheduled payments. Anyone who might want to delay a payment needs to act at least 12 months ahead, so reach them early.
The week-by-week Q4 timeline
The table assumes a window that opens in the first week of November and closes in the first week of December. Shift the weeks if your window runs earlier or later; keep the spacing.
| Week | Benefits team actions | What eligible employees should be doing |
|---|---|---|
| Early October, weeks 1 to 2 | Finalize materials and have counsel review them. Test the enrollment site with the recordkeeper. Confirm the eligibility file. | Nothing yet |
| Mid-October, week 3 (two to three weeks before the window) | Turn on decision support. Send a "start modeling now" note with the calculator link and the window dates. Schedule live sessions. | Gather pay, bonus and tax information; review last year's election |
| Late October, week 4 | Send the plan highlights: what is new, deferral limits, payout options, employer credits. Restate that elections are irrevocable for the year. | Model scenarios: deferral percentage, payout schedule, a possible state move |
| November, week 1 | Open the window. Hold the first live session. Send the launch email. | Model first, then elect |
| November, week 2 | Send reminder 1. Publish a short FAQ built from questions received. Hold office hours. | Elect, or revisit the model with updated bonus estimates |
| November, week 3 | Review completion counts from the recordkeeper. Send a targeted reminder to eligible employees who have not acted. | Finish elections, including payout elections |
| November, week 4 | Send a lighter holiday-week reminder. Escalate any system issues. | Last chance to model before the final week |
| December, week 1 | Send a final reminder 48 hours before close. Close the window on your internal deadline. | Confirm the election was submitted |
| December, week 2 | Issue confirmations. Run a short correction period for errors the plan allows. Check that payout elections are complete. | Review the confirmation statement |
| December, weeks 3 to 4 | Lock elections. Send payroll the deferral file. December 31 is the legal deadline. | Nothing further |
| January | Verify the first payroll with new deferrals. Run a cycle review. Restart the newly-eligible process. | Check the first paycheck |
Completion counts come from your recordkeeper. A private modeling tool should not report who modeled what, and NQDC Calculator does not; sponsors never see individual inputs, results or elections.
Evergreen, distribution and subsequent elections
Three plan features change what your calendar needs to cover.
Evergreen or annual elections. Some plans carry an election forward until the participant changes it; others require a new election every year, so doing nothing means deferring nothing. Your plan document says which applies. With evergreen elections, tell employees plainly that last year's choice will repeat. With annual elections, make sure no one misses the window by assuming it will.
Distribution elections. Many plans ask participants to choose when and how each year's deferrals will be paid at the same time they elect the deferral, for example at separation or on a specified date, as a lump sum or in installments. Payout choices drive the tax result as much as the deferral amount does, so give employees time and tools to compare schedules. The lump sum vs. installments guide is a useful link to include in materials.
Subsequent deferral elections. Changing a payment that has already been elected is possible only under the 12-month and five-year rules. These requests do not follow the open enrollment calendar. They follow each participant's payment dates, which is why the Q3 step of identifying upcoming scheduled payments matters.
Off-cycle windows: new hires, promotions and bonuses
Open enrollment is the main event, but not the only one.
- Newly eligible employees. New hires and promotions into eligibility can elect within 30 days under 409A, if your plan allows it. Build a standing process: an eligibility trigger from HR, a welcome packet, a decision-support link and a hard date for the election. These employees get no group sessions and no reminder campaign, so they may need more help.
- Performance bonus deferrals. If your plan uses the 6-month rule for qualifying performance-based pay, you may run a second window mid-year. Treat it as a smaller version of the Q4 calendar: announce, model, elect, confirm.
- Fiscal-year differences. If your bonus or plan year does not follow the calendar year, map the 409A deadlines to your own dates with counsel and your recordkeeper.
When employees need modeling support most
For many employees, the hard questions surface only as the deadline approaches: how much to defer, which payout schedule to choose and whether the tax savings are worth the risk. They are also questions your team should not answer for them.
The surveys show the gap. In the 2026 Newport/PLANSPONSOR survey, 82% of sponsors were satisfied with their NQDC communication, yet 70% of participants said they still did not understand the plan, and irrevocable election rules were cited as a barrier by 27%.
Opening decision support two to three weeks before the window does three things:
- It moves the hard thinking before the deadline rush, so employees arrive at the election screen with a number in mind.
- It reduces one-off spreadsheet questions to your team during the busiest weeks.
- It keeps your communications on the education side of the line, because each employee models their own situation and the tool never recommends an election. See NQDC investment education vs. advice.
The business case, simply stated. You already pay to administer the plan and run the enrollment. If more eligible employees make an informed election rather than skipping the window, you get more value from a benefit you are already funding. Your plan document governs all deadlines and options, so build the final calendar with counsel, your recordkeeper and your advisers. For the employee-side question your participants will be asking, link to how much to defer.
Frequently asked questions
When is NQDC open enrollment?
For calendar-year plans, the window typically runs in the fall, because 409A generally requires elections for next year's salary by December 31. Your plan sets the exact dates and can close the window earlier to give payroll time.
Can employees change an NQDC deferral election after the window closes?
Generally no. Once the deadline passes, the election for that year is irrevocable, apart from narrow exceptions in the plan and the 409A rules. That is why modeling before electing matters so much.
How long should the NQDC enrollment window be?
There is no required length. A window of three to five weeks, preceded by two to three weeks of modeling time, gives employees room to decide and gives your team a buffer before December 31.
What happens when someone becomes eligible mid-year?
Under 409A, a newly eligible participant can generally elect within 30 days of becoming eligible, if the plan allows it. Set up a standing process so new hires and promotions get the same materials and tools as the annual group.
When do bonus deferral elections need to be made?
Ordinary bonuses follow the prior-year deadline. Performance-based compensation with a performance period of at least 12 months can be elected as late as 6 months before the period ends, if your plan allows it. Confirm with counsel which of your bonus programs qualify.