Determine which Form 5500 to file (5500, 5500-SF, or 5500-EZ), required schedules, filing deadline, and DOL/IRS late penalty calculator for 401k, pension, and welfare plans.
Form 5500 Filing Requirements
Most employee benefit plans subject to ERISA must file an annual report with the DOL via the EFAST2 electronic filing system. The correct form version depends on participant count and plan type.
Form Selection Thresholds
Form 5500-EZ: Solo 401(k) owner-only plans with assets over $250,000
Form 5500-SF: Small plans (under 100 participants) β simplified schedules
Form 5500: Large plans (100+ participants) β full schedules, requires audit
Due Dates (Calendar-Year Plans)
Regular deadline: July 31, 2026. Extended deadline (Form 5558 required): October 15, 2026. Plan year end other than Dec 31: last day of 7th month after plan year end.
Frequently Asked Questions
Which version of Form 5500 do I need to file?
The version depends on your plan type and participant count. Form 5500 (standard): large plans with 100 or more participants at the start of the plan year, or plans required to have an independent auditor. Form 5500-SF (Short Form): small plans with fewer than 100 participants that meet certain conditions including no employer securities held. Form 5500-EZ: one-participant plans (owner-only with no common-law employees) β but only required if plan assets exceed $250,000 at the end of the plan year. SIMPLE 401(k) plans and SEP plans generally do not require Form 5500 filing under normal conditions.
When is Form 5500 due and how do I get an extension?
Form 5500 is due by the last day of the seventh month after the plan year ends. For calendar-year plans (ending December 31), the deadline is July 31 of the following year. A 2.5-month extension can be obtained by filing Form 5558 (Application for Extension of Time to File Certain Employee Plan Returns) by the regular due date, extending to October 15 for calendar-year plans. If the employer's corporate return extension is automatic, the Form 5500 due date is automatically extended to match. However, extension to file is not extension to pay any required taxes.
What are the penalties for late or non-filing of Form 5500?
Both the DOL and IRS impose separate penalties for failure to timely file Form 5500. DOL penalty under ERISA: $250 per day (increased from $25 in 2016), with a maximum of $150,000 per plan year per plan. IRS penalty under IRC 6652(e): $250 per day, maximum $150,000 per plan year. These penalties run concurrently, so the effective combined maximum can reach $300,000 per plan per year. The DOL's Delinquent Filer Voluntary Compliance Program (DFVCP) offers reduced penalties β typically $250 per day, capped at $1,500 (small plans) or $4,000 (large plans) β for late filers who come forward voluntarily before DOL notification.
What schedules are required with Form 5500?
Schedule requirements vary by plan type. Schedule A (Insurance Information): required if any benefits are provided through insurance contracts. Schedule C (Service Provider Information): required for large plans to report service providers receiving $5,000+ in compensation. Schedule D (DFE/Participating Plan Information): for plans in master trust arrangements. Schedule H (Financial Information): required for large plans β full balance sheet and income statement. Schedule I (Financial Information β Small Plans): simpler financial data for plans with fewer than 100 participants. Schedule R (Retirement Plan Information): required for defined benefit plans and some defined contribution plans. Schedule SB or MB: actuarial information for defined benefit plans.
Do small plans need an independent audit?
Plans with 100 or more participants at the beginning of the plan year are "large plans" and must engage an independent qualified public accountant (IQPA) to audit the plan's financial statements and attach the audit report to Form 5500. Plans with fewer than 100 participants are generally "small plans" exempt from the audit requirement. There is a 80/120 rule: plans that had between 80 and 120 participants at the start of the prior plan year may continue to file as a small plan (without audit) even if they cross the 100-participant threshold, as long as the plan was previously filed as a small plan.