Updated May 2026 · PBGC + DOL Form 5500
Critical Risk Pension Plans
Plans designated as critical by PBGC or with severe underfunding. These face the highest probability of benefit reductions or insolvency.
11 pension plans currently sit in the critical-risk tier — covering 1,324,002 active and retired participants with an average funding ratio of 34.2%. These plans either carry a PBGC at-risk or Critical-status designation or report funding ratios deep in the critically underfunded band.
Critical PBGC risk represents the highest formal risk category — plans facing mandatory rehabilitation under federal pension rules. 11 plans hold this designation.
PBGC risk classification applies primarily to private single-employer and multi-employer plans. Public-sector plans operate under state oversight rather than PBGC, so the risk signal there comes from state-level fiscal monitors instead of the federal scheme. For participants, the PBGC classification matters because it signals both the immediate intervention probability and the longer-term benefit-guarantee outlook. Each plan page below links to its full PBGC status and funding history.
What "Critical Risk" Means in Practice
Critical-risk plans are those PBGC has designated as Critical or Critical-and-Declining under PPA (multiemployer) or as deeply at-risk under ERISA Section 430(i) (corporate single-employer). These designations trigger federal contribution and benefit-restructuring rules. Critical multiemployer plans must adopt a Rehabilitation Plan; corporate plans funded below 70% face benefit-distribution and amendment restrictions. Public plans never receive a PBGC critical designation but may show parallel stress in their funding ratios and ACFR disclosures.
The 11 listed plans report a combined $250.6B in unfunded liability — the dollar gap between plan assets and the present value of accrued benefit obligations at each plan's assumed discount rate.
For ERISA-covered private and multiemployer plans, risk classifications draw from PBGC publications and from DOL Form 5500 Schedule SB or MB filings, which disclose the actuarial valuation, the assumed return rate, and any at-risk or Critical-status designation. For public plans, risk reads come from the Public Plans Database compilation of ACFR data, since public plans are not subject to PBGC.
None of this content is investment advice. Participants concerned about a specific plan should review the most recent Annual Funding Notice (mailed annually under ERISA Section 101(f)) and consult a fee-only fiduciary advisor before making any decision about a benefit election or rollover.
Plans at Critical Risk
| # | Plan Name | Type | State | Participants | Funding Ratio | Unfunded Gap | Grade |
|---|---|---|---|---|---|---|---|
| 1 | Illinois Teachers Retirement System (TRS) State of Illinois | public | IL | 424,000 | 44.7% | $77.7B | D |
| 2 | State Universities Retirement System of Illinois (SURS) State of Illinois | public | IL | 218,000 | 44.1% | $28.5B | D |
| 3 | State Employees Retirement System of Illinois (SERS) State of Illinois | public | IL | 152,000 | 40.4% | $29.2B | D |
| 4 | Kentucky Employees Retirement System (KERS) State of Kentucky | public | KY | 142,000 | 20.4% | $28.1B | F |
| 5 | Connecticut State Employees Retirement System (SERS) State of Connecticut | public | CT | 112,000 | 38.2% | $23.0B | D |
| 6 | Bakery & Confectionery Union Industry International Pension Fund BCTGM International Union | multiemployer | MD | 100,402 | 41.8% | $4.1B | D |
| 7 | Chicago Teachers Pension Fund City of Chicago | public | IL | 69,000 | 42.8% | $16.6B | D |
| 8 | Chicago Municipal Employees Annuity & Benefit Fund City of Chicago | public | IL | 59,000 | 25.3% | $18.0B | F |
| 9 | Chicago Policemen's Annuity & Benefit Fund City of Chicago | public | IL | 31,000 | 23.3% | $15.8B | F |
| 10 | Chicago Firefighters Annuity & Benefit Fund City of Chicago | public | IL | 13,500 | 19.5% | $7.8B | F |
| 11 | Judges Retirement System of Illinois State of Illinois | public | IL | 3,100 | 35.2% | $1.8B | D |
How Risk Classifications Are Determined
For ERISA-covered private and multiemployer plans, classifications come from PBGC publications and from the at-risk and Critical-status designations disclosed on Schedule SB and Schedule MB of Form 5500. For public plans, classifications are derived from funding ratio and 3-year funding trend, since public plans are not subject to PBGC. The Pension Health Score weights PBGC risk at 20% of the composite, alongside funding ratio (50%) and trend (30%). Read the full methodology.
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Frequently Asked Questions
What does "Critical Risk" mean for a pension plan?
Plans designated as critical by PBGC or with severe underfunding. These face the highest probability of benefit reductions or insolvency. Critical-risk plans are those PBGC has designated as Critical or Critical-and-Declining under PPA (multiemployer) or as deeply at-risk under ERISA Section 430(i) (corporate single-employer). These designations trigger federal contribution and benefit-restructuring rules. Critical multiemployer plans must adopt a Rehabilitation Plan; corporate plans funded below 70% face benefit-distribution and amendment restrictions. Public plans never receive a PBGC critical designation but may show parallel stress in their funding ratios and ACFR disclosures.
How many pension plans are at critical risk level?
PensionRisk currently classifies 11 pension plans at critical risk. The top 11 are listed below by participant count and unfunded liability, covering 1,324,002 active and retired participants in aggregate.
What is the PBGC and how does it set risk classifications?
The Pension Benefit Guaranty Corporation is a federal agency that insures private-sector defined-benefit pensions. PBGC publishes a list of multiemployer plans in Critical or Critical-and-Declining status under PPA, and a separate framework for corporate single-employer plans designated as at-risk under ERISA Section 430(i). Plans funded below 80% are at-risk, and plans below 70% face stricter rules including amendment and lump-sum distribution restrictions. PBGC publications and the agency's annual report are available at pbgc.gov.
Are public pensions PBGC-rated?
No. Public pension plans — those sponsored by state, county, or municipal governments — are not subject to ERISA or PBGC. They have no federal risk classification. PensionRisk applies a low PBGC-risk default to public plans for the purpose of computing the Pension Health Score; the actual risk signal for public plans comes from funding ratio, 3-year trend, and the sponsor's contribution discipline as reported in each system's ACFR.
Where does the underlying data come from?
Risk classifications come from PBGC publications for ERISA-covered plans and from PensionRisk's composite scoring for public plans (low PBGC-risk default, with funding ratio and trend driving the overall risk read). Funding ratios come from DOL Form 5500 Schedule SB or MB and the Boston College Public Plans Database. The current dataset reflects filings available as of May 2026.
11 pension plans currently sit in the critical-risk tier — covering 1,324,002 active and retired participants with an average funding ratio of 34.2%. These plans either carry a PBGC at-risk or Critical-status designation or report funding ratios deep in the critically underfunded band.