eligibility question

An employer has the standard eligibility requirement of 1 Year of Service (12-month wait with 1000 hours) and age 21. And there are semi-annual entry dates. 

An employee is hired July 20, 2024 and completes a Year of Service on July 20, 2025 but they do not turn 21 until Sept 15, 2025.

Does this person entry the plan on January 1, 2026 or September 15, 2025.  SPD language is below.  It seems to imply January 1, 2026 but we want to be conservative if there is any ambiguity.

Thank you!

Tom

It is Age AND Service, so September 15, 2025 is when they first meet both the Age AND Service conditions. The they will enter the first entry date  after September 15, 2025. If it is calendar year plan with first day of plan year and first day of 7th month that would be January 1, 2026.

edited to take into account David Rigby comment.

2 hours ago, Lou S. said:

The first entry date after September 15, 2025 is January 1, 2026.

Well, assuming the plan uses "January 1" as a defined Entry Date.   However, it might use "December 31".  Verify.

There is no ambiguity here per the SPD, the entry is not retroactive to when they met only one of the two conditions. Participation begins on the next Entry Date after both are met.