Form 5500-EZ vs. 5500-SF vs. Full 5500: Which Version Your Plan Files

9/23/2026

There are three versions of the annual return for a retirement plan, and choosing the wrong one is not a formatting problem. A one-participant plan that files a 5500-SF has not filed the return it owes. A small plan that files the short form while holding an asset that disqualifies it has filed an incomplete return. A plan that crosses the 100-participant line without noticing can miss a required independent audit.

The choice comes down to three questions, asked in order:

Who does the plan cover? If only the owner (and spouse) or only partners (and spouses), it is a one-participant plan, and the answer is Form 5500-EZ, or no filing at all.
How many participants does it have? Fewer than 100 at the start of the plan year (with an 80-120 carry-forward rule) makes it a small plan.
Does a small plan meet every condition for the short form? If yes, Form 5500-SF. If not, the full Form 5500 with small-plan schedules.

This guide works through each step, with the thresholds from the current IRS and DOL instructions. For what the annual return contains and how it is filed generally, see our Form 5500 primer.

The Quick Answer

Plan situation	Version	Filed with
Covers only owner/spouse or partners/spouses; total one-participant plan assets $250,000 or less at year end; not the final year	No filing required	None
Covers only owner/spouse or partners/spouses; assets over $250,000, or final plan year	Form 5500-EZ	IRS on paper, or EFAST2 (required for filers with 10+ IRS returns)
Covers employees; fewer than 100 participants; meets every 5500-SF condition	Form 5500-SF	EFAST2 only
Covers employees; fewer than 100 participants; fails any 5500-SF condition	Form 5500 (small plan, Schedule I)	EFAST2 only
Covers employees; 100 or more participants (subject to the 80-120 rule)	Form 5500 (large plan, Schedule H, audit)	EFAST2 only

All three versions share the same due date: the last day of the seventh month after the plan year ends, which is July 31 for a calendar-year plan, extendable by up to 2½ months with Form 5558.

Step 1: Is It a One-Participant Plan?

The definition

The Form 5500-EZ instructions define a one-participant plan as a retirement plan (a defined benefit plan, or a defined contribution profit-sharing or money purchase plan, other than an ESOP) that:

Covers only you, or you and your spouse, and you (or you and your spouse) own the entire business, incorporated or not; or
Covers only one or more partners, or partners and their spouses, in a partnership (a more-than-2% shareholder of an S corporation is treated as a partner for this purpose);

and provides benefits for no one else.

This is the "solo 401(k)" or individual 401(k) most self-employed people use, and it also covers owner-only defined benefit and cash balance plans. Because these plans cover no common-law employees, they are not subject to ERISA Title I, which is why they do not file through the DOL's standard Form 5500 process.

Certain foreign plans maintained outside the US primarily for nonresident aliens also use Form 5500-EZ when they have an IRS filing obligation.

One-participant plans cannot use the 5500-SF

This is the point most often missed. The 5500-EZ instructions are explicit: a one-participant plan cannot file an annual return on Form 5500 or Form 5500-SF, regardless of whether the plan filed one of those forms in the past. The IRS's Form 5500 corner page makes the same point. A 5500-SF filed for a one-participant plan does not satisfy the plan's filing obligation, and amended returns for such a plan are filed on Form 5500-EZ even if the original was filed on 5500-SF.

The $250,000 threshold

A one-participant plan does not have to file Form 5500-EZ for a plan year if the total assets of that plan, combined with all other one-participant plans maintained by the employer, are $250,000 or less at the end of the plan year, unless it is the plan's final year.

Three details matter:

It is an end-of-year test. The instructions measure total plan assets at the end of the plan year, as reported on the form. A plan that was above $250,000 in June and below it on December 31 is under the threshold for that year.
It is aggregated. An owner with both a solo 401(k) and an owner-only cash balance plan adds the two together. If the combined total is over $250,000, a Form 5500-EZ is due for each one-participant plan, including the one with less than $250,000 on its own.
The final year always files. When the plan terminates and distributes all its assets, a final Form 5500-EZ is required regardless of the balance. Many small plans that never filed before must file once, at the end.

How to file Form 5500-EZ

Form 5500-EZ can be filed on paper with the IRS (mailed to the IRS in Ogden, Utah) or electronically through EFAST2. For plan years beginning on or after January 1, 2025, electronic filing through EFAST2 is mandatory for a filer required to file at least 10 returns of any type with the IRS during the calendar year that includes the first day of the plan year. Information returns such as Forms W-2 and 1099, income tax returns, employment tax returns and excise tax returns all count. A filer subject to the mandate who files on paper is treated as not having filed.

That rule catches more one-participant plans than people expect. A business owner whose company files quarterly Forms 941, several Forms 1099 and its own income tax return can easily reach 10.

Form 5500-EZ filers do not attach schedules. A one-participant defined benefit or cash balance plan must still have a completed and signed Schedule SB prepared and kept in its records, and must still perform the annual valuation, even though the schedule is not filed.

Information from Form 5500-EZ, paper or electronic, is not published on the internet.

When the plan stops being one-participant

A solo 401(k) stays a one-participant plan only while it covers no one but owners and their spouses (or partners and their spouses). When the business hires employees who meet the plan's eligibility conditions and enter the plan, it becomes an ERISA plan covering employees, and the filing moves to Form 5500-SF or Form 5500 through EFAST2. Whether an employee must be covered depends on the plan document's eligibility terms and the coverage rules, so this is a question for the plan's provider or TPA at the time of the first hire, not at filing time.

Late 5500-EZ filings

Late Form 5500-EZ filings face the IRS penalty under Code section 6652(e): $250 a day, up to $150,000 per plan year. The DOL's Delinquent Filer Voluntary Compliance Program is not available to Form 5500-EZ filers. Instead, the IRS runs a penalty relief program under Rev. Proc. 2015-32: the fee is $500 per delinquent return, up to $1,500 per plan per submission. Delinquent returns under the program must be filed on paper (not through EFAST2) with Form 14704 attached to the front of the oldest return, and marked as the instructions describe.

Step 2: Small Plan or Large Plan?

For any plan that covers employees, the next question is size. A plan with fewer than 100 participants at the beginning of the plan year is a small plan. A plan with 100 or more is a large plan.

How to count

For a defined contribution plan such as a 401(k), the current DOL instructions count participants with account balances at the beginning of the plan year. An eligible employee who has never deferred and never received an employer contribution does not count. A plan's first-year return uses its end-of-year count instead.

For a defined benefit plan, including a cash balance plan, the count includes everyone: active participants, retirees and beneficiaries receiving benefits, and separated participants entitled to future benefits.

The 80-120 rule

If the participant count is between 80 and 120 and the plan filed a Form 5500 (or 5500-SF) for the prior year, it may elect to file in the same category as the prior year. A plan that filed as small can keep filing as small, including on the 5500-SF if it is otherwise eligible, until its count passes 120. Once it files as large, it can remain large until the count drops below 80.

What changes for a large plan

A large plan files the full Form 5500 with Schedule H (full financial statements) and generally must engage an independent qualified public accountant to audit the plan and attach the report. It also files Schedule C if any service provider received $5,000 or more in direct or indirect compensation, and Schedule G for certain problem transactions. The audit is the largest cost difference between small and large plans, and the one most worth managing toward through the participant count.

Step 3: Does a Small Plan Qualify for the 5500-SF?

The 5500-SF is a short form that combines the main return and a streamlined financial section. A small plan may file it only if it meets every condition in the DOL's instructions. Paraphrasing the 2025 instructions, the plan must:

Have covered fewer than 100 participants at the beginning of the plan year, or be eligible under the 80-120 rule to file as a small plan and cover no more than 120;
Not hold employer securities at any time during the plan year;
Be 100% invested in "eligible plan assets" at all times during the year. These are assets with a readily determinable fair value, such as mutual fund shares, investment contracts with insurance companies and banks valued at least annually, publicly traded securities held by a registered broker-dealer, cash and cash equivalents, and participant loans;
Be eligible for the waiver of the independent audit under 29 CFR 2520.104-46, but not by reason of enhanced bonding. The waiver conditions include giving participants certain disclosures about the plan's investments;
Not be a multiemployer plan;
Not be required to file Form M-1 (for multiple-employer welfare arrangements);
Not be a pooled employer plan; and
Not be filing as, or part of, a defined contribution group (DCG) reporting arrangement.

ESOPs and direct filing entities cannot use the 5500-SF either.

Common disqualifiers

Hard-to-value assets. Real estate, a limited partnership interest, a privately held company's stock, or a self-directed brokerage window holding something unusual. One non-qualifying asset at any point in the year disqualifies the short form for that year.
Employer stock. Any employer securities, even a small amount.
Reliance on enhanced bonding for the audit waiver. A plan that qualifies for the audit waiver only because it carries an enhanced fidelity bond over non-qualifying assets is not eligible for the 5500-SF.

A plan that fails any condition still files as a small plan, on the full Form 5500 with Schedule I (small-plan financial information) and any other applicable schedules, such as Schedule A for insurance contracts and Schedule D for pooled investments.

Defined benefit plans on the 5500-SF

A small single-employer defined benefit or cash balance plan that meets every condition can file the 5500-SF, but it must attach Schedule SB and its required attachments. Small multiple-employer plans also attach Schedule MEP.

Payroll's Part in Getting the Version Right

The version decision usually rests with the TPA, but payroll and HR supply the facts it depends on:

Who is covered. The moment a solo plan covers an employee, its filing changes. HR should tell the plan provider about every new hire who may become eligible.
The participant count. Terminated employees with small balances keep the count up. A plan sitting near 100 participants should review distributions of small balances, under the plan's terms, before the start of the year.
Contribution totals. Deferrals and employer contributions reported on any version of the form should be consistent with payroll records and the box 12 amounts on Forms W-2. Our year-end reconciliation guide covers the payroll side of that reconciliation.
Late deposits. Every version that covers employees asks whether participant contributions were transferred to the plan on time. Our 401(k) plan administration handbook explains the deposit timing rules.

Frequently Asked Questions

Who needs to file Form 5500-EZ?

A one-participant plan files Form 5500-EZ: a retirement plan that covers only the business owner (or owner and spouse) who own the entire business, or only partners and their spouses, with no other participants. Certain foreign plans also use it. A one-participant plan must file only if the combined year-end assets of all of the employer's one-participant plans exceed $250,000, or if it is the plan's final year. Plans that cover employees file Form 5500 or 5500-SF through EFAST2 instead.

What is the $250,000 rule for Form 5500-EZ?

A one-participant plan does not need to file Form 5500-EZ for a plan year if its total assets at the end of the year, combined with the assets of all other one-participant plans the employer maintains, are $250,000 or less. If the combined total exceeds $250,000, every one of those plans must file, including any plan that is below $250,000 on its own. The exemption never applies in the plan's final year: a terminating plan files a final Form 5500-EZ regardless of its balance.

Can a solo 401(k) file Form 5500-SF instead of 5500-EZ?

No. The current Form 5500-EZ instructions state that a one-participant plan cannot file its annual return on Form 5500 or Form 5500-SF, even if it filed one of those forms in the past. A one-participant plan must file Form 5500-EZ, either on paper with the IRS or electronically through EFAST2. Electronic filing is mandatory for plan years beginning on or after January 1, 2025 if the filer must file at least 10 returns of any type with the IRS during the calendar year.

Who is eligible to file Form 5500-SF?

A plan that covers employees may file the 5500-SF if it had fewer than 100 participants at the start of the year (or qualifies under the 80-120 rule), held no employer securities, was invested entirely in eligible plan assets with a readily determinable fair value, and qualifies for the small-plan audit waiver without relying on enhanced bonding. Multiemployer plans, pooled employer plans, plans in a DCG reporting arrangement, ESOPs and plans required to file Form M-1 cannot use it.

What happens if Form 5500-EZ is filed late?

The IRS penalty under Code section 6652(e) is $250 a day, up to $150,000 per plan year. The DOL's Delinquent Filer Voluntary Compliance Program is not available for Form 5500-EZ. Instead, the IRS penalty relief program under Rev. Proc. 2015-32 lets filers catch up for $500 per delinquent return, capped at $1,500 per plan per submission. Returns filed under the program must be submitted on paper, with Form 14704 attached and the returns marked as the instructions describe.

When is Form 5500-EZ due?

Form 5500-EZ is due on the same schedule as Form 5500 and 5500-SF: the last day of the seventh month after the plan year ends, which is July 31 for a calendar-year plan. If that date falls on a weekend or legal holiday, it moves to the next business day. Form 5558 extends the deadline by up to 2½ months if filed by the original due date, and an automatic extension to the employer's extended tax return due date is available when the plan year and tax year match.

Building the Skills Behind the Filing

Choosing the right version is the last step of a year of plan operations: tracking who is eligible, counting participants correctly and keeping payroll and plan records in agreement. The 401(k) Training and Certification Program covers 401(k) plan administration for payroll and HR professionals. For related reading, see Payroll and Retirement Plans and the retirement plan contribution limits for 2026.

Filing thresholds and procedures are set in each year's instructions. Check the current Form 5500, 5500-SF and 5500-EZ instructions before you file.