Start Up Safe Harbor 3% QNEC

Establishing new safe harbor 401(k) plan. Have established 401(k) effective for October 1st, using 3% QNEC.  Effective date of Plan January 1, 2020.

Employer mistook when the first payroll would be in October.  Instead of being October 8th it is October 1st (actual payroll date).  The enrollment meeting scheduled for September 30th, after when the October 1st payroll will be called in.  Next payroll to be paid October 15th (bi-weekly).

I see nothing except the "3 month rule".  And find no exceptions.

As we are using the QNEC for the safe harbor does anyone have an opinion on delaying until October 15th the first 401(k) deferral from employee's pay?

Any assistance or thoughts greatly appreciated.

Ask the client to run the payroll on 9/30 instead of 10/1?

Sometime the easiest solution is the best solution.  Thanks Lou.