Form 8955-SSA is the annual registration statement a retirement plan files to report participants who left employment with a vested benefit still in the plan. The IRS passes the information to the Social Security Administration (SSA), which gives it back to those individuals when they apply for Social Security benefits. It is how a former employee, decades later, finds out that a plan from an old job still owes them money.
It is a narrow form, and it is employer-only. Participants never see it except through the SSA. But it has its own penalties, its own filing system and its own mandatory e-filing rule, and it is built almost entirely on termination data that originates in payroll and HR. When it goes wrong, it is usually because the separation dates, Social Security numbers or names the plan received were wrong.
This guide covers who files, which participants to report, timing alongside Form 5500, how to file, the penalties and the data trail from payroll.
Form 8955-SSA satisfies the reporting requirement of Internal Revenue Code section 6057(a). It replaced the old Schedule SSA to Form 5500, which the IRS says should no longer be filed under any circumstances. Form 8955-SSA is now used for all years, including late filings for plan years before 2009.
Three features separate it from Form 5500:
The plan administrator of any plan subject to the vesting standards of ERISA section 203 must file. In practice that includes:
Plans not subject to ERISA's vesting rules, such as governmental plans, non-electing church plans, and plans covering only owners and their spouses or only partners and their spouses, are not required to file. They may file voluntarily.
A Form 8955-SSA need not be filed for a year if there is nothing to report for that year.
For a plan to which only one employer contributes (which includes a controlled group, a group under common control or an affiliated service group treated as one employer), a participant must be reported if they:
The participant must be reported no later than the Form 8955-SSA for the plan year following the plan year in which they separated. You may report them earlier, on the form for the year of separation. That one-year lag exists so that participants who take a distribution shortly after leaving drop out before they are ever reported.
For example, in a calendar-year plan, an employee who terminates in March 2025 with a vested balance must be reported no later than the 2026 Form 8955-SSA, which is due by July 31, 2027 (without extension). If they take a full distribution before that filing is due, they do not need to be reported at all.
A participant who has not been reported before does not need to be reported if, before the form's due date (including extensions), they:
There is a trap in the first item: if payments stop before the full vested benefit is paid, the remaining benefit must be reported on the form for the plan year following the last year in which payment stopped.
Multiemployer plans, multiple-employer plans and collectively bargained plans with more than one contributing employer follow a different trigger. A participant is reported once they incur two consecutive one-year breaks in service (as the plan defines them for vesting) and are, or may be, entitled to a deferred vested benefit. The form also has a checkbox for participants whose information is based on incomplete service records.
Each participant listed on page 2 gets an entry code:
|
Code |
Use it for |
|
A |
A participant not previously reported |
|
B |
Correcting information for a participant previously reported under this plan |
|
C |
A participant previously reported under another sponsor's plan whose benefit was transferred (not rolled over) into this plan |
|
D |
A participant previously reported under this plan who is no longer entitled to the benefit (paid out, began receiving benefits, or transferred to another plan) |
Code D is the one plans forget. If a former employee was reported in a prior year and has since taken a lump sum, the plan should report them with code D so the SSA's record stops telling them they have a benefit waiting. A change in account value alone does not need to be reported under code B. Participants should not be reported under code D merely because they were rehired.
When a plan terminates, the Form 8955-SSA for its final year must report the status of previously reported deferred vested participants, including that they are no longer deferred vested.
For each participant the form asks for:
Page 1 carries the plan, sponsor and administrator identifiers. Those must match the Form 5500. The plan sponsor's EIN and the three-digit plan number must be the same ones used on Form 5500, and any change in the sponsor's or administrator's name or EIN since the last filing must be disclosed on the form, or the IRS may send correspondence.
The plan sponsor and the plan administrator both sign the form. If they are the same person, only the administrator's signature is needed.
The due date matches the Form 5500 deadline: the last day of the seventh month after the plan year ends, which is July 31 for a calendar-year plan. If the date falls on a weekend or legal holiday, file on the next business day.
A filer must file Form 8955-SSA electronically if it is required to file 10 or more returns of any type with the IRS during the calendar year that includes the first day of the plan year. "Returns" for this count include information returns such as Forms W-2 and 1099, income tax returns, employment tax returns (each quarterly Form 941 counts) and excise tax returns.
That threshold is easy to reach. An employer that files four Forms 941 and at least six Forms W-2 in the year is already there. If a filer required to e-file submits paper instead, the IRS treats the form as not filed, even though a paper form was submitted. The IRS may waive the requirement for undue economic hardship on a year-by-year basis.
The 2025 instructions describe these routes:
Paper filers must use the standard page 2 for participant listings. The SSA no longer processes nonstandard pages or spreadsheets.
The penalties are statutory and are set out in the IRS instructions:
|
Failure |
Penalty |
|
Failure to file, or failure to include all required participants (section 6652(d)(1)) |
$10 per participant not reported, per day, up to $50,000 |
|
Failure to file a notification of a change in plan status or administrator (section 6652(d)(2)) |
$10 per day, up to $10,000 |
|
Willful failure to furnish the participant statement, or a willfully false statement (section 6690) |
$50 per failure |
Penalties do not apply if the failure is shown to be due to reasonable cause.
The plan administrator must also give each participant being reported an individual statement with the same information, no later than the due date of the form. Line 8 of the form asks whether this was done. Many recordkeepers generate the statement, but the administrator is responsible for it.
Form 8955-SSA is usually prepared by the plan's recordkeeper or TPA, but the inputs come from the employer's systems:
Termination dates. The separation date drives which year's form a participant belongs on. A termination keyed late, or a leave of absence never converted to a termination, moves participants into the wrong year or keeps them off the form.
Rehire dates. A rehired former employee who returns to covered service should not be reported, and should not be reported under code D either. If the rehire never reaches the recordkeeper, the plan reports someone it should not.
Names and SSNs. The SSA matches on name and number. The name must appear exactly as on the Social Security card. If payroll ran an SSN verification at hire, use that record. Our W-2 preparation guide covers name and SSN accuracy, and the same discipline applies here.
Addresses. Not reported on the form, but needed for the participant statement and for tracking down missing participants later.
Distribution status. A former employee paid out before the due date drops off the list. Final paycheck processing and distribution requests often move through different teams. Coordinate them so the recordkeeper knows who was paid.
A simple control: each year, before the recordkeeper prepares the form, reconcile the list of terminated employees in payroll against the plan's list of separated participants with balances. Differences point to missing terminations, unreported rehires or misapplied distributions. The payroll year-end checklist is a natural place to add that step, and the record retention guidance in payroll recordkeeping requirements applies to the termination records behind it.
Form 8955-SSA reports participants who separated from service with a vested benefit that has not been paid. The IRS shares the information with the Social Security Administration, which gives it to those individuals when they apply for Social Security benefits, so they know a former employer's plan may owe them a benefit. Plans subject to ERISA's vesting standards must file it, including 401(k), profit-sharing, defined benefit, cash balance and ERISA-covered 403(b) plans. It is filed with the IRS, separately from Form 5500, and is not open to public inspection.
Form 8955-SSA is due on the last day of the seventh month after the plan year ends, July 31 for a calendar-year plan. That is the same date as Form 5500. Form 5558 filed by the normal due date gives a one-time extension of up to 2½ months. An automatic extension to the employer's extended tax return due date also applies when the plan year matches the employer's tax year. Extending Form 5500 does not automatically extend Form 8955-SSA; the extension request must cover it.
For a single-employer plan, report each participant who separated from covered service and is entitled to a deferred vested benefit that has not been paid. The report is due no later than the form for the plan year following the year of separation, though you may report earlier. Participants who are paid, return to service or forfeit their benefit before the form's due date do not need to be reported. Multiemployer and multiple-employer plans report after two consecutive one-year breaks in service.
It does if the filer is required to file 10 or more returns of any type with the IRS during the calendar year that includes the first day of the plan year. Forms W-2, Forms 1099, quarterly Forms 941 and income tax returns all count toward the 10, so most employers with employees meet the threshold. A filer subject to the mandate who files on paper is treated as not having filed. Electronic filing goes through the IRS FIRE system, usually through approved software.
Under Code section 6652(d)(1), the penalty is $10 for each participant not reported, for each day the failure continues, up to $50,000. Failing to report a change in plan status or in the administrator's name or address carries $10 a day, up to $10,000. Separately, a willful failure to give a participant their individual statement, or a willfully false statement, is $50 per failure under section 6690. Penalties do not apply where the failure is due to reasonable cause.
Code A reports a participant for the first time: someone who separated with a deferred vested benefit and has not been reported before. Code D removes a previously reported participant who is no longer entitled to the deferred benefit, because they took a lump sum, started receiving benefits or had their benefit transferred to another plan. Using code D keeps the SSA's records accurate. Without it, a former employee may later be told they have a benefit that was paid out years ago.
Form 8955-SSA is only as good as the termination, rehire and distribution data behind it, and that data starts in payroll and HR. The 401(k) Training and Certification Program covers 401(k) plan administration from the employer's side, including the distribution and termination processing this form depends on. For the wider picture of how payroll and the plan interact, see the 401(k) plan administration handbook and Payroll and Retirement Plans.
Filing methods and instructions are revised each year. Check the current Instructions for Form 8955-SSA on IRS.gov before you file.

