Updated October 1, 2026. Quick answer: Form 5500-SF is the short version of the annual plan report. A plan can use it only if it is a small plan, generally under 100 participants at the beginning of the plan year, and it meets several other tests: no required audit by an independent accountant, all assets in certain secure investments with a readily determinable value, no employer securities, and not a multiemployer plan, a pooled employer plan or part of a group reporting arrangement. A plan that fails any test files the full Form 5500. Both are filed electronically through EFAST2.
The size test
The instructions put it this way: “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.” A plan with 100 or more participants at that date is a large plan and files the full form.
Plans near the line get a cushion: “If the number of participants is between 80 and 120, and a Form 5500 Annual Return/Report was filed for the prior plan year, you may elect to complete the return/report in the same category” as the year before. The instructions give the example of a plan that filed as a small plan for 2024 and counts 120 or fewer participants for 2025.
The other tests
Size alone is not enough: “In addition to the limitation on the number of participants, a Form 5500-SF may only be filed for a plan that is exempt from the requirement that the plan’s books and records be audited by an independent qualified public accountant (but not by reason of enhanced bonding), has 100 percent of its assets invested in certain secure investments with a readily determinable fair market value, holds no employer securities, is not a multiemployer plan, is not required to file a Form M-1 (Report for Multiple-Employer Welfare Arrangements (MEWAs) and Certain Entities Claiming Exception (ECEs)) for the plan year, is not a pooled employer plan, and is not filing as part of a DCG reporting arrangement.”
The instructions point to the separate Form 5500-SF instructions, under Who May File Form 5500-SF, for the full detail. This page reads only the main Form 5500 instructions.
What a small plan files instead
A small plan that does not use the short form files the full form with a financial schedule for small plans. The instructions say that schedule “is required for all pension benefit plans and welfare benefit plans filing the Form 5500 Annual Return/Report, rather than the Form 5500-SF,” as small plans. In the other direction, “Plans that file a Form 5500-SF for the 2025 plan year are not required to file a Schedule H for that year.”
The three forms side by side
| Form | Who files it | How it is filed and the EZ penalty |
|---|---|---|
| Full Form 5500 | 100 or more participants, or a small plan that fails a Form 5500-SF test | Electronic only, through EFAST2 |
| Form 5500-SF | A small plan, generally under 100 participants, that meets every test | Electronic only, through EFAST2 |
| Form 5500-EZ | An owner-only plan; no return at or below $250,000 in assets unless it is the final year | EFAST2 or paper; late penalty $250 a day, up to $150,000 |
The first two rows follow the Form 5500 instructions; the $250,000 test and the penalty in the third row come from the Form 5500-EZ instructions, covered on the Form 5500-EZ page.
One-participant plans
An owner-only plan has its own form. The Form 5500-EZ instructions say what happens when that form is not available: “you must electronically file Form 5500 or, if eligible, Form 5500-SF.” An amended return has a restriction: “Do Not use Form 5500-SF for an amended return of a one-participant plan or a foreign plan, even if you previously filed using Form 5500-SF.” More is on the Form 5500-EZ page.
How each form is filed
The two main forms are electronic only: “you must electronically file the 2025 Forms 5500 and 5500-SF using EFAST2’s web-based filing system or you may file through an EFAST2-approved vendor.” The owner-only form has an option the others lack: “The 2025 Form 5500-EZ can also be electronically filed using the EFAST2 filing system or filed on paper with the IRS.”
Common mistakes
- Assuming any plan under 100 participants can use the short form. The audit, investment and structure tests must also be met.
- Holding employer stock in the plan and still using Form 5500-SF.
- Amending a one-participant plan return on Form 5500-SF.
Related: the Form 5500 instructions, the Form 5500 due date and extension, Form 5500-EZ for one-participant plans, 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.