What Is Form 5500? Who Files, What's Reported and When It's Due

9/19/2026

Form 5500 is the annual return/report for an employee benefit plan. It is one filing that serves three agencies at once: the Department of Labor (DOL), the IRS and the Pension Benefit Guaranty Corporation (PBGC). It reports who the plan covers, what it holds, what came in and went out, who was paid to run it, and whether the plan met a list of compliance conditions during the year.

For most employers the form arrives as a draft from a recordkeeper or third-party administrator (TPA) and gets signed with a quick look. That is a mistake. The plan administrator signs it under penalty of perjury. The answers are public. And several lines are effectively confessions: late deposits of employee deferrals, missed contributions, a missing fidelity bond. Many of those answers come straight from payroll data.

This guide covers which plans file, how plan size is counted, which version and schedules apply, how the form is filed, when it is due and what happens when it is late.

Who Has to File Form 5500

The filing obligation comes from ERISA sections 104 and 4065 and Internal Revenue Code section 6058(a). The general rule in the DOL's instructions is broad: the administrator or sponsor of any employee benefit plan subject to ERISA must file information about each plan every year.

Retirement (pension benefit) plans

In practice this covers:

401(k) and profit-sharing plans, including safe harbor designs
Money purchase pension plans
ERISA-covered 403(b) plans (403(b) arrangements that are not ERISA plans, such as many governmental and church plans, do not file)
Traditional defined benefit plans
Cash balance plans, which are defined benefit plans for filing purposes

The instructions exclude several types of arrangement. Examples include SIMPLE IRA plans, SEPs that use the alternative method of compliance, governmental plans, non-electing church plans, unfunded top-hat plans for a select group of management or highly compensated employees that filed the DOL registration statement, and most plans maintained outside the US for nonresident aliens.

One-participant plans (a plan covering only a business owner and spouse, or only partners and their spouses) are not ERISA Title I plans. They do not file Form 5500. When they have a filing obligation it is on Form 5500-EZ, which has its own asset threshold. We cover the version choice in detail separately, but the short version is in the table below.

Welfare plans

Health, dental, life, disability and severance plans also file Form 5500. Here the main exemption is for size: a welfare plan that covered fewer than 100 participants at the beginning of the plan year and is unfunded, fully insured or a mix of the two generally does not file. A self-funded health plan using a trust, or any welfare plan with 100 or more participants, generally does. Welfare plans that must file a Form M-1 (multiple-employer welfare arrangements) lose the small-plan exemption.

This article focuses on retirement plans, because that is where payroll data drives most of the form.

Small Plan vs. Large Plan: How Participants Are Counted

Almost everything about the filing depends on whether the plan is a "small plan" or a "large plan." The dividing line is 100 participants at the beginning of the plan year.

The counting method is where people go wrong. For a defined contribution plan, such as a 401(k), the current DOL instructions count participants who have account balances at the beginning of the plan year (Form 5500 line 6g(1)). The instructions describe these as participants who made a contribution, or for whom a contribution was made, in the current or any prior plan year. An employee who is eligible but has never deferred and never received an employer contribution does not count toward the 100. A plan filing its first return uses the end-of-year count with balances instead.

For defined benefit plans, including cash balance plans, the count is the total participant figure on line 5. That includes active employees, retirees and separated participants who are entitled to future benefits.

Two exceptions matter in practice:

The 80-120 rule. If the participant count is between 80 and 120 and a Form 5500 was filed for the prior year, the plan may elect to file in the same category it used the year before. A plan that filed as small last year can keep filing as small until it passes 120.

The short plan year rule. If either the prior or current plan year was seven months or less, the plan can elect to defer the accountant's report, under conditions in 29 CFR 2520.104-50.

Why it matters: a large plan generally needs an audit by an independent qualified public accountant (IQPA), files the full financial Schedule H, and may need Schedules C and G. A small plan files the lighter Schedule I or, if it qualifies, the short Form 5500-SF, and is usually eligible for the audit waiver.

The count is a payroll problem. The recordkeeper's participant count depends on the census payroll sends. Terminated employees with small balances that were never cashed out keep the count up. Plans that sit near 100 often manage the number through automatic force-outs of small balances, where the plan document allows them. That decision belongs to the plan sponsor, made with the TPA, and should be made before the beginning-of-year count is taken, not after.

Which Version: Form 5500, 5500-SF or 5500-EZ

Version	Who uses it	Where it is filed
Form 5500	Large plans; small plans that do not meet every 5500-SF condition	EFAST2 (electronic only)
Form 5500-SF	Small plans meeting all eligibility conditions	EFAST2 (electronic only)
Form 5500-EZ	One-participant plans and certain foreign plans	IRS on paper, or EFAST2 (mandatory for filers with 10+ IRS returns)

The 5500-SF ("short form") is available only to small plans that meet every condition in the DOL instructions, including: no employer securities held during the year, 100% of assets in "eligible plan assets" such as mutual funds, bank or insurance investment contracts valued at least annually, publicly traded securities held by a registered broker-dealer, cash and participant loans, and eligibility for the small-plan audit waiver (not by reason of enhanced bonding). Multiemployer plans, pooled employer plans, ESOPs and plans filing as part of a defined contribution group (DCG) arrangement cannot use it.

What Form 5500 Reports: The Main Schedules

The main form identifies the plan, the sponsor, the administrator, the plan year, participant counts and plan characteristic codes. The detail lives in schedules, and which ones attach depends on size and plan type.

Schedule A: Insurance Information

Required when any benefits are provided through an insurance company or similar organization, including insurance investment contracts such as guaranteed investment contracts and pooled separate accounts. A 401(k) plan invested through a group annuity contract will have one; a welfare plan with insured coverage will typically have one per contract. Insurers are required to provide the information, but the plan administrator files it.

Schedule C: Service Provider Information

Required for large plans when any service provider received $5,000 or more in compensation, directly or indirectly, from the plan during the year, or when an accountant or enrolled actuary was terminated. Indirect compensation (revenue sharing, 12b-1 fees, commissions) is where this schedule earns its reputation. Small plans do not file Schedule C.

Schedule D: DFE/Participating Plan Information

Lists investments in master trusts, common/collective trusts, pooled separate accounts and 103-12 investment entities.

Schedule G: Financial Transaction Schedules

Large plans only, when Schedule H reports loans or fixed income obligations in default, leases in default or nonexempt (prohibited) transactions.

Schedule H: Financial Information (large plans)

The full balance sheet and income statement for the plan, plus compliance questions. Large plans also attach the IQPA report and supporting schedules, including a schedule of delinquent participant contributions where applicable.

Schedule I: Financial Information (small plans)

The small-plan version, filed by small plans that use the full Form 5500 rather than the 5500-SF.

Schedule R: Retirement Plan Information

Required for defined benefit plans and plans subject to the minimum funding rules, and in some cases for other pension plans. It covers distributions, funding and certain plan amendments.

Schedules SB and MB: Actuarial Information

Schedule SB carries the actuarial information for most single-employer defined benefit plans, including cash balance plans, and is signed by an enrolled actuary. Schedule MB is the multiemployer equivalent and applies to some money purchase plans amortizing a funding waiver. The instructions list a separate IRS penalty for failing to file a required actuarial statement.

There are also schedules for multiple-employer plans (Schedule MEP) and DCG arrangements (Schedule DCG).

The Compliance Questions Payroll Feeds

The financial schedules contain yes/no questions that the DOL reads closely. Several trace directly back to payroll and HR processes:

Were participant contributions transferred to the plan late? Employee deferrals and loan repayments withheld from pay become plan assets once they can reasonably be segregated from the employer's general assets. Late remittances are reported on the form and are a common DOL finding. Our 401(k) plan administration handbook covers deposit timing from the payroll side.
Did the plan have a fidelity bond? ERISA requires bonding for people who handle plan funds.
Were there nonexempt transactions with a party in interest? Late deposits are also a prohibited transaction, so the same failure can show up twice.
Did the plan fail to provide benefits when due?
Were there participant loans, and are any in default?

Contributions also appear as dollar totals. Employee deferrals reported on the plan's return should be consistent with what payroll withheld and reported in box 12 of Forms W-2 for the year (allowing for timing differences across plan and calendar years). Examiners notice when they are not. Our IRS payroll audit guide lists retirement plan data inconsistent with payroll as one route into an employment tax examination, and our W-2 preparation guide covers the box 12 codes.

How Form 5500 Is Filed: EFAST2

Form 5500 and Form 5500-SF must be filed electronically through the DOL's ERISA Filing Acceptance System, EFAST2. Paper filing is not accepted. Filers use EFAST2's web-based system or an EFAST2-approved software vendor, which is what most TPAs use. Signers need EFAST2 credentials, and the plan administrator (and the employer, where required) signs electronically.

A few practical points:

The administrator must keep a copy of the filed return, with schedules, attachments and signatures, in the plan's records.
Filed Forms 5500 and 5500-SF are made available to the public. Anyone, including participants, competitors and plaintiffs' attorneys, can look up a plan's filings.
Form 5500-EZ filings for one-participant plans are not published on the internet, whether they are filed on paper or through EFAST2.

When Form 5500 Is Due

The due date is the last day of the seventh calendar month after the plan year ends. For a calendar-year plan, that is July 31. If the date falls on a weekend or federal holiday, the filing is due the next business day. A short plan year follows the same rule, counted from the end of the short year.

Extensions

Form 5558 gives a one-time extension of up to 2½ months, which moves a calendar-year plan's deadline to October 15. It must be filed on or before the normal due date. Since January 1, 2025, Form 5558 can be filed electronically through EFAST2 or on paper with the IRS. Keep a copy, because the IRS does not return approved extensions.
Automatic extension to the employer's extended federal income tax return due date applies if the plan year and the employer's tax year are the same, the employer has an extension for its return that runs past the normal Form 5500 due date, and a copy of that extension is kept with the plan records. This automatic extension cannot be stretched with a Form 5558, and no extension can run more than 9½ months past the end of the plan year.
Special extensions are announced by the IRS, DOL and PBGC for presidentially declared disasters and combat zone service.

An extension of Form 5500 does not extend PBGC premium filings or the separate Form 8955-SSA deadline, even though Form 5558 can be used for both forms.

Penalties for Late or Missing Filings

Penalties come from two directions.

DOL. Under ERISA section 502(c)(2), the DOL can assess a daily civil penalty against a plan administrator who fails or refuses to file a complete and accurate report. The maximum is adjusted for inflation every year; the 2025 instructions list it at up to $2,739 a day, with no cap. Check the current figure on the DOL's website, because the instructions themselves warn that it may change after they are published. The DOL also rejects filings it considers deficient, and a rejected filing can be treated as not filed.

IRS. Code section 6652(e) imposes $250 a day, up to $150,000 per plan year, for late filing. A separate $1,000 penalty under section 6692 applies to each failure to file a required actuarial statement (Schedule SB or MB).

Getting current: DFVCP

The DOL's Delinquent Filer Voluntary Compliance Program (DFVCP) lets administrators catch up on late filings by paying a reduced penalty before the DOL notifies them of the failure. According to the DOL, the basic penalty is $10 a day, capped at $750 per filing and $1,500 per plan for small plans, and $2,000 per filing and $4,000 per plan for large plans, with a lower per-plan cap for small plans sponsored by 501(c)(3) organizations. The IRS generally gives penalty relief to filers who complete DFVCP. Form 5500-EZ filers cannot use DFVCP. They have a separate IRS program.

Building a 5500 Calendar That Works

The filing itself is usually prepared by the TPA. The employer's job is getting accurate inputs to them early enough to fix problems before the deadline. A workable annual cycle for a calendar-year 401(k) plan:

January to February: reconcile year-end payroll deferral and match totals to what the recordkeeper received. Our year-end reconciliation guide covers the payroll side.
February to March: send the census (hire, termination and rehire dates, hours, compensation on the plan's definition, ownership and family relationships) for testing. A census built from the wrong compensation definition will pass through the 5500 unnoticed and fail somewhere else.
Spring: large plans schedule the IQPA audit. Auditors sample payroll records, so expect requests for registers, deferral elections and deposit records.
June: review the TPA's draft. Check participant counts, contribution totals and every compliance question, especially late deposits and bonding.
By July 31: file, or file Form 5558 and calendar October 15.
After filing: a summary annual report goes to participants for most plans that file (defined benefit plans that provide the annual funding notice are handled differently). Diary the next year's cycle.

Frequently Asked Questions

What is Form 5500 used for?

Form 5500 is the annual return/report for an ERISA employee benefit plan. It satisfies reporting requirements of the DOL, IRS and PBGC in one filing. It reports the plan's participants, financial condition, investments, service provider fees and compliance with key rules such as timely deposit of employee contributions and fidelity bonding. Retirement plans such as 401(k), 403(b), defined benefit and cash balance plans file it, as do many welfare plans. Filings are public and can be searched by anyone, which is why plan sponsors should review the draft carefully rather than signing it unread.

When is Form 5500 due?

Form 5500 is due by the last day of the seventh calendar month after the plan year ends. For a calendar-year plan, that is July 31. Filing Form 5558 by the normal due date gives a one-time extension of up to 2½ months, to October 15 for a calendar-year plan. An automatic extension to the employer's extended income tax return due date is also available when the plan year and tax year match and the employer has an extension on file. No extension can go beyond 9½ months after the plan year ends.

Does a small 401(k) plan have to file Form 5500?

Yes. A 401(k) plan covering employees other than the owner and spouse files every year regardless of size. What changes with size is the version. A plan with fewer than 100 participants with account balances at the beginning of the year is a small plan. It can file the shorter Form 5500-SF if it meets all the eligibility conditions, and it is usually exempt from the independent audit. A plan covering only the owner and spouse, or only partners, files Form 5500-EZ instead, and only when assets pass the threshold.

What is the difference between Schedule A, Schedule C and Schedule H?

Schedule A reports insurance contracts, including insured benefits and investment contracts with insurance companies. Schedule C applies only to large plans and lists service providers paid $5,000 or more, directly or indirectly, from the plan, including revenue sharing and commissions. Schedule H is the large-plan financial statement, with assets, liabilities, income, expenses and compliance questions, and it is accompanied by the independent accountant's report. Small plans filing the full Form 5500 use Schedule I instead of Schedule H.

What is the penalty for filing Form 5500 late?

There are two separate exposures. The IRS penalty under Code section 6652(e) is $250 a day, up to $150,000 per plan year. The DOL can assess a daily civil penalty under ERISA section 502(c)(2) that is adjusted for inflation each year and has no overall cap; the 2025 instructions list it at up to $2,739 a day. Late filers who come forward before the DOL contacts them can use the Delinquent Filer Voluntary Compliance Program, which caps the penalty per filing and per plan.

Who signs Form 5500?

The plan administrator signs, and in many cases the employer/plan sponsor signs too. Both sign electronically in EFAST2 using their own credentials. Signatures are made under penalty of perjury, and a TPA or recordkeeper preparing the return does not shift that responsibility. The plan administrator named in the plan document is usually the employer itself unless the document names someone else. The signed copy, with all schedules and attachments, must be kept in the plan's records.

Learn to Run the Annual Reporting Cycle

Form 5500 is the place where a year of plan operation gets written down: eligibility, deferrals, deposits, loans and distributions. If you handle the payroll or HR side of a 401(k), the 401(k) Training and Certification Program covers 401(k) plan administration, and the 401(k) Procedures Manual and e-Alerts adds a desk reference. For how retirement plans interact with payroll more broadly, see Payroll and Retirement Plans and IRS and DOL audits.

Penalty amounts and filing procedures change from year to year. Work from the current-year Form 5500 instructions on the DOL's EFAST2 website.