Form 5500 is the annual report that employee benefit plans file with the Department of Labor, IRS, and PBGC. Plans with 100 or more eligible participants must file Form 5500 (large plan filing) with audited financial statements attached. Plans with fewer than 100 participants file Form 5500-SF (small plan filing) and are generally exempt from the audit requirement.
Every ERISA-covered employee benefit plan with at least one participant must file a Form 5500 or Form 5500-SF annually. The form reports the plan's financial condition, investments, and operations for the plan year. For large plans (100+ participants), this includes audited financial statements prepared by an independent CPA firm.
Missing the filing deadline or filing without the required audit attachment triggers penalties from both the DOL ($250/day, up to $150,000) and the IRS (up to $250/day, uncapped). For the audit itself, see what is an employee benefit plan audit and 401(k) audit requirements.
Who files: The plan administrator (usually the employer) is responsible for filing. Third-party administrators (TPAs) often prepare the filing, but the plan administrator is legally responsible.
Filing deadline: The last day of the 7th month after the plan year ends. For calendar-year plans, that's July 31. An automatic 2.5-month extension is available by filing Form 5558, pushing the deadline to October 15 for calendar-year plans.
How to file: All Form 5500 filings must be submitted electronically through the EFAST2 system at efast.dol.gov. Paper filings are not accepted.
Large plan filing (Form 5500): Plans with 100+ eligible participants at the beginning of the plan year must attach audited financial statements (Schedule H) and the auditor's report. This is the "large plan" filing.
Small plan filing (Form 5500-SF): Plans with fewer than 100 eligible participants file the simplified Form 5500-SF, which does not require an audit. Small plans must still meet certain conditions (like having all assets in qualifying plan assets) to use the simplified filing.
The 80-120 transition rule: Plans hovering near 100 participants can use the 80-120 rule to avoid switching between small and large filings year to year. If you filed as small last year and have between 80-120 participants this year, you can continue filing as small.
Schedule H (Financial Information): Large plans report assets, liabilities, income, and expenses. The audited financial statements attach here.
Schedule I (Financial Information - Small Plan): Small plans report simplified financial data without an audit requirement.
Schedule C (Service Provider Information): Reports compensation paid to service providers (recordkeepers, investment managers, TPAs) who received $5,000+ in direct or indirect compensation from the plan.
Schedule R (Retirement Plan Information): Reports plan distributions, funding information, and plan characteristics specific to retirement plans.
Schedule MB/SB (Actuarial Information): Required for defined benefit plans to report actuarial valuations and funding status.
DOL penalties: $250 per day for late or incomplete filings, up to $150,000 per filing. The DOL's Delinquent Filer Voluntary Compliance Program (DFVCP) offers reduced penalties for plans that self-correct late filings before being notified by the DOL.
IRS penalties: $250 per day for failure to file, with no statutory cap. The IRS also has a penalty relief program for late filers.
PBGC penalties: Defined benefit plans that fail to file required PBGC premiums or notifications face additional penalties.
For the tools that help CPA firms process Form 5500 audit evidence, see best audit software for CPA firms. For extracting data from the underlying plan documents, see best payroll data extraction software and best financial document automation.
Form 5500 is the annual report that employee benefit plans file with the Department of Labor, IRS, and PBGC. It reports the plan's financial condition, investments, operations, and compliance for the plan year. Every ERISA-covered benefit plan with at least one participant must file annually through the EFAST2 electronic filing system.
An audit is required when the plan has 100 or more eligible participants at the beginning of the plan year. These 'large plans' file Form 5500 with audited financial statements attached to Schedule H. Small plans (fewer than 100 participants) file Form 5500-SF without an audit requirement.
Form 5500 is due by the last day of the 7th month after the plan year ends. For calendar-year plans, that's July 31. A 2.5-month extension is available by filing Form 5558, extending the deadline to October 15 for calendar-year plans.
DOL penalties are $250 per day, up to $150,000 per filing. IRS penalties are $250 per day with no statutory cap. The DOL's DFVCP program and IRS penalty relief programs offer reduced penalties for voluntary self-correction before being contacted by the agencies.
Plans that filed as small the previous year can continue filing as small (no audit required) if they have between 80 and 120 eligible participants. This prevents plans from bouncing between small and large filings when headcount fluctuates near 100. Once you file as large, you stay large until participants drop below 80.
%20(1).svg)
