On 16 May 2024, the government published updated guidance regarding the UK Sustainability Disclosure Requirements (SDR) framework. The SDR was first set out in Greening.
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In a previous blog article, we alerted readers to the extension of deadlines related to COBRA, Special Enrollment, Plan Disclosures and more. The prior Joint Notice from the DOL and IRS provided suspension of
all deadlines until 60 days after the expiration of the National Emergency, referred to as the “Outbreak Period.”
The issue requiring clarification arose due to the unanticipated length of the Outbreak Period. Much like all of us, the IRS and DOL did not foresee an Outbreak Period continuing well over a year later. As the one-year anniversary of the Outbreak Period approached, a conflict began to arise with ERISA section 518 and Code section 7508A(b). Those provisions generally provide that the Secretaries of Labor and the Treasury may prescribe extensions of