Updated October 1, 2026. Quick answer: Form 5500 is the annual report that almost every employer retirement or benefit plan covered by ERISA must file, whether or not any money went in that year. The 2025 form is filed during 2026 for plan years that began in 2025, and it must be filed electronically through the EFAST2 system, not on paper. It is due by the last day of the seventh month after the plan year ends, which is July 31 for a calendar-year plan. Small plans may use the shorter Form 5500-SF, and plans that cover only an owner and spouse use Form 5500-EZ.
More IRS forms and schedules, read line by line: Form 5330 instructions.
Who has to file
The general rule in the instructions is: “A return/report must be filed every year for every pension benefit plan, welfare benefit plan, and for every entity that files as a DFE as specified below”. It applies even in a quiet year: “report must be filed whether or not the plan is “tax-qualified,” benefits no longer accrue, contributions were not made this plan year, or contributions are no longer made.”
Pension plans on the list include “Profit-sharing plans, stock bonus plans, money purchase plans, 401(k) plans, etc.” Welfare plans are covered too: “Welfare benefit plans provide benefits such as medical, dental, life insurance, apprenticeship and training, scholarship funds, severance pay, disability, etc.”
Plans that do not file a Form 5500
The instructions list pension plans that are exempt. Three that come up often are “A Savings Incentive Match Plan for Employees of Small Employers (SIMPLE) that involves SIMPLE IRAs under Code section 408(p).” “A simplified employee pension (SEP) or a salary reduction SEP described in Code section 408(k) that conforms to the alternative method of compliance in 29 CFR 2520.104-48 or 2520.104-49.” and “A governmental plan.” A church plan that has not elected coverage is also exempt. Exemption depends on the exact plan type and the conditions in the instructions, so confirm yours before skipping the filing.
A plan that covers only an owner and spouse, or only partners, is a one-participant plan. The instructions say “certain one-participant plans are required to file the Form 5500-EZ”. See the Form 5500-EZ page.
Filing is electronic only
The instructions open with the filing method: “Your 2025 Form 5500 must be electronically filed in the ERISA Filing Acceptance System (EFAST2).” “You cannot file a paper Form 5500 by mail or other delivery service.” For help, “The EFAST2 Help Desk is available Monday through Friday from 8:00 am to 8:00 pm, Eastern Time.”
When it is due
The rule: “All required forms, schedules, statements, and attachments must be filed by the last day of the 7th calendar month after the end of the plan, DCG or GIA year (not to exceed 12 months in length) that began in 2025.” “If the filing due date falls on a Saturday, Sunday, or Federal holiday, the return/report may be filed on the next day that is not a Saturday, Sunday, or Federal holiday.”
| Plan year ends (computed here) | Normal due date |
|---|---|
| December 31 | July 31 |
| September 30 | April 30 |
| June 30 | January 31 |
The dates in that table apply the seventh-month rule to three common year-ends; they are calculated for this page, not listed by the agencies. The extension rules are on the Form 5500 due date page.
Which year’s form to use
The 2025 form covers plan years that began in 2025. The instructions anticipate a gap when the next year’s form is late: “If the 2026 Form 5500 is not available before the plan or DFE filing is due, use the 2025 Form 5500 and enter the 2026 fiscal year beginning and ending dates on the line provided at the top of the form.”
Small plans and one-participant plans
Plans that fit certain conditions can file less. “If you are a small plan (generally under 100 participants at the beginning of the plan year), you may be eligible to file the Form 5500-SF instead of the Form 5500.” The conditions are on the Form 5500-SF versus full Form 5500 page.
Penalties at a glance
| Item | Amount in the 2025 instructions |
|---|---|
| DOL penalty for a late or incomplete report | Up to $2,739 a day |
| IRS penalty for certain deferred compensation plans | $250 a day, up to $150,000 |
| Reduced-penalty route for late Title I filers | Delinquent Filer Voluntary Compliance (DFVC) Program |
Penalties for filing late or incomplete
Administrative penalties apply to late or incomplete filings. The Department of Labor can assess “A penalty of up to $2,739 a day for each day a plan administrator fails or refuses to file a complete and accurate report.” The instructions add that the amount is adjusted for inflation: “be sure to check DOL’s website for any possible required inflation adjustments of the maximum penalty amount that may have been published in the Federal Register after the instructions have been posted.”
The IRS side is separate: “A penalty of $250 a day (up to $150,000) for not filing returns for certain plans of deferred compensation, trusts and annuities, and bond purchase plans by the due date(s).” A reduced-penalty route exists for late filers: “The DFVC Program facilitates voluntary compliance by plan administrators who are delinquent in filing annual reports under Title I of ERISA by permitting administrators to pay reduced civil penalties for voluntarily complying with their DOL annual reporting obligations.”
Common mistakes
- Skipping the filing because no contributions were made. The instructions say the report is required regardless.
- Preparing a paper Form 5500. The form must be filed through EFAST2.
- Assuming every small plan is exempt. Exemptions turn on plan type, not just size.
Related: the Form 5500 due date and extension, Form 5500-SF versus the full Form 5500, Form 5500-EZ for one-participant plans, 401(k) fees by plan size, and Form 5500 Schedule C.
Sources
- Instructions for Form 5500 (2025), Annual Return/Report of Employee Benefit Plan (DOL, IRS and PBGC): https://www.dol.gov/sites/dolgov/files/EBSA/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500/2025-instructions.pdf
- IRS Instructions for Form 5500-EZ (2025): https://www.irs.gov/pub/irs-pdf/i5500ez.pdf
- IRS Form 5558 (Rev. January 2025), Application for Extension of Time To File Certain Employee Plan Returns: https://www.irs.gov/pub/irs-pdf/f5558.pdf
Read from the DOL, IRS and PBGC documents linked above on October 1, 2026. General information, not tax advice. Your own facts decide the outcome, and a preparer, the account provider or the IRS is the right place to confirm anything consequential.