Form 5500 is one of those filings that doesn’t announce itself until something goes wrong. Miss the deadline, attach the wrong schedule, or miscount your participants, and suddenly you’re looking at IRS penalties, DOL notices, and a correction process that eats up time your team doesn’t have.

This guide covers what you need to file it right: which version applies to your plan, when it’s due, how to get through EFAST2 without surprises, and what to do if something’s already gone sideways. 

If you’re still figuring out whether your plan needs an audit at all, start with our 401(k) audit requirements guide. For a full walkthrough of the audit process itself, see our EBP audit preparation guide.

What is Form 5500?

Form 5500 is the annual report that employee benefit plans file to document their financial condition, operational status, and compliance with federal law. It’s required under both the Employee Retirement Income Security Act (ERISA) and the Internal Revenue Code, and it gives the DOL, IRS, and PBGC the information they need to protect plan participants.

Think of it as a financial and compliance snapshot: everything from plan assets and contributions to distributions and service provider fees.

Who must file?

Most employers sponsoring ERISA-covered retirement plans (such as 401(k), pension, profit-sharing, and many 403(b) plans) are required to file a Form 5500 annually, as are many health and welfare plans, including medical, dental, vision, and life insurance coverage (subject to certain small-plan and special-plan exceptions). Plans must continue filing for every year they remain in existence and hold assets until a final Form 5500 is filed, even if no contributions were made during that year.

One distinction worth noting for health and welfare plans: unfunded or fully insured welfare plans with fewer than 100 participants at the beginning of the plan year are generally exempt from filing. But once a welfare plan has 100 or more participants at the beginning of the plan year, it generally must file Form 5500, and if the plan is funded through a trust, additional financial reporting and audit requirements can apply. Many employers do not realize their health plan has a Form 5500 obligation until a DOL audit surfaces it.

Who’s exempt?

A few categories don’t need to file: government entity plans, church plans, plans maintained outside the US for non-US citizens, and plans established solely for compliance with unemployment, workers’ compensation, or disability laws.

Which Form 5500 Do You Need?

There are three versions of Form 5500. The right one depends on how many participants your plan covers.

Form 5500 — Large plans (100+ participants)

If your plan had 100 or more participants on the first day of the plan year, this is your form. It requires electronic filing through EFAST2, includes the full set of schedules, and requires an independent audit report as an attachment.

Form 5500-SF — Small plans (fewer than 100 participants)

The simplified version for smaller plans. It covers the same core reporting requirements with fewer schedules and no audit attachment required in most cases. Also filed electronically through EFAST2.

Form 5500-EZ — One-participant plans

For plans covering only a business owner and their spouse, no other employees. Only required if plan assets exceed $250,000. This is the only version that can still be filed by mail, though EFAST2 is also available.

The 80-120 rule gives plans that recently crossed 100 participants some flexibility on maintaining small-plan status. Our 401(k) audit requirements guide covers exactly how that works and when it applies.

Form 5500 Filing Deadlines

When you file depends on your plan year. Here’s how the deadlines break down.

  • Standard deadline: The last day of the seventh month after the plan year ends. For calendar-year plans, that’s 31 July. For fiscal-year plans, count seven months from your plan year-end date.
  • Extension: File Form 5558 by the original deadline to receive a 2.5-month extension. For calendar-year plans, that pushes the deadline to 15 October.

One practical note for fiscal-year plans: if your business has an automatic extension of time to file its federal income tax return, that extension automatically applies to Form 5500 as well. You don’t need to file a separate Form 5558 in that situation, but you do need to confirm the extension is in place before your original deadline passes.

What if you’ve already missed the deadline?

If you’ve missed the deadline, file anyway. Late is always better than never, and significantly cheaper, depending on how you handle it. The Delinquent Filer Voluntary Compliance Program (DFVCP) allows plan sponsors to come forward proactively and pay a reduced penalty, capped well below what the DOL can otherwise assess. The window closes the moment you receive a written notice from the DOL, so don’t wait.

Form 5500 Penalties: What’s Actually At Stake

The IRS can assess $250 per day for each day a Form 5500 is late, up to a maximum of $150,000 per plan year under IRC Section 6652(e). That same penalty applies to incomplete returns – a filing with missing schedules or blank required fields is treated the same as a late filing.

The DOL penalty is a separate and more severe exposure. Under the Federal Civil Penalties Inflation Adjustment Act, the DOL can assess approximately $2,670 per day (adjusted annually for inflation), with no maximum cap. These penalties run independently. Both DOL and IRS penalties can apply to the same late filing at the same time.

In practice, the DOL has discretion on how much it actually assesses and tends to reserve maximum penalties for egregious violations. But the exposure is real, and plans that delay filing or ignore notices can face six-figure consequences.

The Delinquent Filer Voluntary Compliance Program (DFVCP)

The DOL’s DFVCP dramatically reduces penalties for plan sponsors who come forward on their own, before the DOL contacts them. Under DFVCP, the penalty rate drops to $10 per day. Per-filing caps apply: $750 for small plans and $2,000 for large plans. If you have multiple delinquent years, the total per-plan cap is $1,500 for small plans and $4,000 for large plans, regardless of how many years are outstanding.

Amended filings

If you discover an error after submitting, you can file an amended Form 5500 through EFAST2. Check “amended return” on Line B, correct the relevant fields and schedules, and resubmit. Amended filings don’t carry a separate penalty if the original was filed on time. If the original was late and you’re also correcting errors, use DFVCP for the delinquency and submit the corrected version simultaneously.

How To Tile Form 5500

Step 1: Get your EFAST2 credentials

Register at www.efast.dol.gov. The registration is a one-time process. You’ll need to select the appropriate filing role: filing author, filing signer, or both. The plan administrator who signs the completed form must have signer credentials, not just author access. This is a common source of last-minute delays; the person who built the filing realizes at the end that they can’t submit it.

Step 2: Gather your information

Before opening EFAST2, collect: plan documents and financial statements, participant count data (beginning and ending of plan year), service provider information and fees paid, SOC 1 reports from your recordkeeper and custodian if applicable, and your audit report if your plan requires one. Having everything organized before you start reduces the risk of leaving required fields incomplete mid-filing.

Step 3: Complete the form in EFAST2

The core fields cover plan identification (name, EIN, plan number), participant counts (beginning and ending of year), and financial data (assets, contributions, distributions, and service provider fees). One field that trips up first-time filers: the plan number. Every plan maintained by the same employer is assigned a unique three-digit number — retirement plans begin at 001, welfare plans begin at 501. A plan number that doesn’t match DOL records results in a rejected filing.

Step 4: Attach the required schedules

Schedules are where the complexity lives. Here’s what each one covers and when it applies.

  • Schedule A reports insurance and annuity contract information. Required if your plan holds any insurance contracts, including group health coverage through an insurer, annuity products, or similar arrangements.
  • Schedule C reports compensation paid to service providers receiving $5,000 or more from the plan, including recordkeepers, investment advisors, and TPAs. Required for large plans. It also covers indirect compensation — fees paid by mutual funds to a recordkeeper as revenue sharing, for example, even if the plan never directly paid that amount. The DOL has made Schedule C accuracy an enforcement focus, and omitting indirect compensation is a frequent finding in DOL investigations.
  • Schedule D applies when a plan’s assets are pooled through a master trust or common collective trust. Required whenever that arrangement is in place.
  • Schedule G covers financial transactions that require additional disclosure: loans or fixed income obligations in default, leases in default, and non-exempt party-in-interest transactions. Only required when those situations exist.
  • Schedule H is the full financial information schedule for large plans, covering assets, liabilities, income, expenses, and transfers. Required for all large plans.
  • Schedule I is the simplified financial information schedule for small plans. It covers the same core data as Schedule H with fewer line items.
  • Schedule R is required for pension and retirement plans. It covers distribution data, funding status, and for defined benefit plans, actuarial information. Required for most defined contribution plans as well.
  • Audit report: For large plans filing Form 5500, the independent auditor’s report must be attached as a PDF. A missing audit report results in an incomplete filing, which carries the same penalty exposure as not filing at all. Our EBP audit preparation guide walks through the full audit process, what auditors examine, and how to get organized well before fieldwork begins.

Step 5: Review and submit

Check participant counts, EINs, and plan numbers against source documents. Confirm that every required schedule is attached and that no required fields are blank. 

Common Form 5500 Errors

  • Participant count errors. Under rules updated in 2023, plans count only participants with an account balance, not all eligible employees. Miscounting can mean filing the wrong form version, missing the audit requirement, or attracting DOL scrutiny. Our 401(k) audit requirements guide covers the counting methodology in detail.
  • Plan status errors. Checking the wrong box for plan status (active, frozen, or terminated) creates compliance issues that require amended filings to correct. Terminated plans have specific final-year filing obligations, and marking a plan as terminated prematurely can trigger unwanted DOL follow-up.
  • Incorrect EIN or plan number. A mismatched EIN or wrong three-digit plan number results in a rejected filing. Both are worth verifying against DOL records before submission, not after.
  • Missing required schedules. An incomplete filing is treated the same as a late filing from a penalty standpoint — the $250/day IRS penalty applies, and the DOL can assess its own penalties separately. Don’t submit until every required schedule is attached.
  • Schedule C omissions. Indirect compensation is the most commonly missed item on Schedule C. If your mutual funds pay revenue sharing to your recordkeeper, that compensation must be disclosed even if the plan didn’t write a check for it. Get this information from your service providers before the filing window opens.
  • Information older than 12 months. All data must reflect the plan year being reported. Carrying forward prior-year figures, particularly for participant counts or asset balances, produces an inaccurate filing.
  • Not using EFAST2. Nearly all plan filers are required to file electronically. Submitting a paper form where EFAST2 is required is treated as a non-filing.

Don’t Forget The Summary Annual Report

Within two months of the Form 5500 deadline, most plan sponsors must also distribute a Summary Annual Report (SAR) to plan participants. For calendar-year plans, that’s 15 September, or 15 November if you filed with an extension.

The SAR is a plain-language summary of the Form 5500 for participants. It covers plan assets, expenses, benefits paid, and participants’ right to request a full copy of the Form 5500. It goes to participants, not the DOL, but it’s an ERISA requirement and one that’s easy to lose track of in the weeks after filing.

Health and welfare plans that are unfunded or fully insured are generally exempt from the SAR requirement. Funded welfare plans that hold assets in trust are not.

How Trullion Simplifies Form 5500 Preparation

When that support lives in spreadsheets and email threads, assembling it under deadline pressure increases the risk of errors and delays.

Trullion helps by structuring the accounting and documentation behind the numbers that flow into Form 5500. Source agreements are centralized, calculations are automated, and every change is tracked — creating a clear audit trail from underlying documentation to financial statement impact.

For large plans requiring an independent auditor’s report, that transparency reduces back-and-forth and helps ensure the financial information stands up to scrutiny before July 31 or October 15 arrives.

Whether you’re submitting the form or supporting it, Trullion helps make Form 5500 preparation faster, cleaner, and more controlled.

See how Trullion simplifies EBP audit prep and execution. Schedule a demo today.

The Bottom Line

Form 5500 is one of the most consequential annual compliance filings for employee benefit plans. The fundamentals are manageable: choose the right form, file electronically by 31 July (or 15 October with an extension), attach every required schedule, and don’t overlook the audit attachment if you’re a large plan.

The plans that manage this process well treat Form 5500 preparation as a year-round activity, not a July scramble. With the right systems in place, the filing is the last step of an organized process, not the moment everything gets pulled together at once.

The plans that get through Form 5500 season without stress aren’t lucky, they’re prepared. See how Trullion helps you get there.

Author

Katie Cavanaugh