match safe harbor after 12/1?

I know I am reaching on this, but could you start a safe harbor match effective 1/1/2022 with the notice going out as late as 12/13/2021?  I know that the rules for proper employee notification would require that notice to be distributed no later than 12/1, but is that a "safe harbor (so-to-speak)" notice deadline?  If the safe harbor match notice is given after that date and if the eligible participants then still have enough time to make a decision, receive education material, ask questions, and are ready to go by January 1, 2022, can that still be considered valid enough to have the safe harbor effective 1/1/2022?  For a small group of employees, this could probably be done.  But would it be considered valid?

From the IRS Website https://www.irs.gov/retirement-plans/notice-requirement-for-a-safe-harbor-401k-or-401m-plan

General Rule: Generally, the safe harbor notice must be provided within a reasonable period before the beginning of the plan year. The timing requirement is deemed to be satisfied if the notice is provided at least 30 days (and not more than 90 days) before the beginning of each plan year. If the notice is not provided within this time frame, whether the notice is timely depends upon all of the relevant facts and circumstances.

If you can document the shorter period is reasonable you would be OK. It could be subject to challenge so the more you could document the steps taken to insure that all participants received the notice and had an effective opportunity to change their deferral elections prior to the next year's first payroll the more likely you will be deemed to have distributed in reasonable time frame before the start of the year. And yes that might be easier to do in a small company than a large one.

As Lou mentioned, it's facts and circumstances if you miss the 12/1 date. But if you can document that a meeting was held, that helps. If you just started the plan, I think that would help. If you had been doing a match, but it's now a SH match, I think that would help. And the further into January that the first paycheck is cut helps as well.

Is this a new plan?  Could then, perhaps, start the deferral portion as of February 1.