When Is Form 5500 Due? Calculating Deadlines & Extensions
Confidently manage your Form 5500 reporting. Understand key timelines and essential steps to ensure timely compliance for your employee benefit plan.
Form 5500 is an annual reporting requirement for employee benefit plans, providing transparency regarding their financial condition and operations. This filing helps ensure compliance with federal regulations set forth by the Employee Retirement Income Security Act (ERISA), the Internal Revenue Service (IRS), and the Department of Labor (DOL). Its purpose is to offer insight into a plan’s management and financial stability, fostering accountability and protecting participant interests.
Understanding Form 5500 and General Filing Requirements
Form 5500 is a document required by the Department of Labor (DOL) that also satisfies reporting obligations for the IRS and the Pension Benefit Guaranty Corporation (PBGC). It provides detailed information about an employee benefit plan’s financial status, investments, and operational activities. This reporting mechanism ensures that plans comply with ERISA and the Internal Revenue Code.
Employers sponsoring retirement plans like 401(k)s, 403(b)s, and pension plans, along with certain welfare benefit plans, must file Form 5500 annually. Welfare plans include medical, dental, vision, life insurance, disability benefits, Health Reimbursement Arrangements (HRAs), and Flexible Spending Accounts (FSAs). The specific Form 5500 version depends on the number of plan participants.
Plans with 100 or more participants at the beginning of the plan year typically require the full Form 5500. Smaller plans, with fewer than 100 participants, may file Form 5500-SF, a simplified short form, provided they meet certain conditions, such as investing assets in eligible plan assets. Form 5500-EZ is for “one-participant plans,” which cover only a business owner and their spouse, or partners and their spouses, with no other employees.
Several exemptions from the Form 5500 filing requirement exist. One-participant plans are generally exempt if their total assets across all such plans do not exceed $250,000 at the end of the plan year, unless it is the plan’s final year. Certain small welfare plans with fewer than 100 participants are exempt if they are unfunded, fully insured, or a combination. Plans established by governmental entities or churches are also typically exempt from ERISA’s reporting requirements.
Forms 5500 and 5500-SF must be filed electronically through the DOL’s EFAST2 system. While Form 5500-EZ can be filed electronically through EFAST2, paper filing with the IRS is also an option for one-participant plans.
Calculating Your Form 5500 Due Date
The standard deadline for filing Form 5500 is the last day of the seventh calendar month following the end of the plan year. This consistent rule helps plan administrators anticipate their filing obligations based on their plan’s fiscal schedule. Adhering to this deadline is important to avoid potential penalties.
For plans operating on a calendar year, where the plan year concludes on December 31, Form 5500 is due by July 31 of the following year. For example, a plan year ending December 31, 2024, has a Form 5500 due date of July 31, 2025.
If a plan operates on a non-calendar fiscal year, the calculation method remains the same. For instance, a plan year concluding on March 31 would have its Form 5500 due by October 31 of that same year.
A practical consideration for all filing deadlines is the weekend and legal holiday rule. If the calculated due date falls on a Saturday, Sunday, or a legal holiday, the deadline automatically shifts to the next business day.
For plans with a short plan year (less than 12 months), Form 5500 is generally due on the last day of the seventh calendar month after that short plan year concludes. For terminated plans, the final Form 5500 is typically due on the last day of the seventh month following plan termination or full asset distribution.
How to File for a Form 5500 Extension
If additional time is needed to complete Form 5500, an extension can be requested by filing Form 5558. This form provides a one-time extension for the Form 5500 series.
Form 5558 must be filed on or before the original Form 5500 due date. For most calendar year plans, this means submitting Form 5558 by July 31. The extension is automatically granted if the form is timely and completely filed, without explicit approval from the IRS or DOL.
Filing Form 5558 generally extends the due date for Form 5500 by 2.5 months. For a calendar year plan due July 31, a timely filed Form 5558 extends the deadline to October 15 of the same year. This additional time can help in gathering necessary documentation and ensuring accuracy.
As of January 1, 2025, Form 5558 can be filed electronically through the EFAST2 system. Filers can also submit a paper Form 5558 by mail to the IRS Service Center in Ogden, Utah. A single Form 5558 can extend the filing time for both Form 5500 and Form 8955-SSA, if applicable.
An automatic extension for Form 5500 may apply if the plan year and the employer’s federal income tax year are the same, and the employer has an extension for its federal income tax return. In such cases, the Form 5500 due date aligns with the extended tax return due date, which could also be October 15 for calendar year entities.