Updated October 1, 2026. Quick answer: Form 5500 is due by the last day of the seventh calendar month after the plan year ends, so July 31 for a calendar-year plan. For the 2025 plan year that was Friday, July 31, 2026. Filing Form 5558 by that date gives an automatic extension to the 15th day of the third month after it, which is Thursday, October 15, 2026. For the 2026 plan year July 31, 2027 is a Saturday, so the normal due date rolls to Monday, August 2, 2027, and the extended date is October 15, 2027.
Related reading on this site: Form 1040 due date 2027 and Form 1065 and 1120-S due date 2027.
More IRS forms and schedules, read line by line: Form 5330 instructions.
The normal due date
The instructions say: “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.”
| Calendar-year plan (all dates computed here) | Normal due date | Day of week | Extended date with Form 5558 | Day of week |
|---|---|---|---|---|
| 2025 (plan year ended December 31, 2025) | July 31, 2026 | Friday | October 15, 2026 | Thursday |
| 2026 (plan year ending December 31, 2026) | July 31, 2027, which is a Saturday, so Monday, August 2, 2027 | Saturday | October 15, 2027 | Friday |
The days of the week and the October dates are calculated for this page by applying the agencies’ rules; they are not printed in the instructions. A fiscal-year plan runs the same seventh-month count from its own year-end.
The Form 5558 extension
The instructions describe the extension: “A plan, GIA, or DCG may obtain a one-time extension of time to file a Form 5500 Annual Return/Report (up to 2½ months) by filing IRS Form 5558, Application for Extension of Time To File Certain Employee Plan Returns, on or before the normal due date (not including any extensions) of the return/report.”
Form 5558 itself says approval is automatic if two conditions are met: “The application is automatically approved to the date shown on line 2 and/or line 3 (above) if (a) the Form 5558 is filed on or before the normal due date of Form 5500 series, and/or Form 8955-SSA for which this extension is requested; and (b) the date on line 2 and/or line 3 (above) is not later than the 15th day of the 3rd month after the normal due date.”
Filing method changed in 2025: “Beginning January 1, 2025, Form 5558 can be filed electronically through EFAST2 or can be filed with the IRS on paper.” “A separate Form 5558 must be used for each plan for which an extension is requested.” Keep a copy: “A copy of the completed extension request must be retained with the filer’s records.”
The income tax extension route
There is a second way to get more time, with conditions: “An automatic extension of time to file the Form 5500 Annual Return/Report until the due date of the federal income tax return of the employer will be granted if all of the following conditions are met:” the plan year and the employer’s tax year are the same, the employer has an extension of its income tax return to a later date, and a copy of that application is kept with the filer’s records. The instructions add that it “CANNOT be extended further by filing a Form 5558, nor can it be extended beyond a total of 9½ months beyond the close of the plan year.”
What an extension does not cover
An extension for the annual report does not extend a separate PBGC deadline: “An extension of time to file Form 5500, Form 5500-SF, Form 5500-EZ, and/or Form 8955-SSA does not operate as an extension of time to file the PBGC (Pension Benefit Guaranty Corporation) Form 1, Annual Premium Payment.” A plan with a one-participant filing also does not send the form with its return: for Form 5500-EZ the instructions say “do not attach Form 5558 to your Form 5500-EZ.”
Penalty figures in the instructions
| Item | Amount |
|---|---|
| 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 |
| Form 5500-EZ late return (IRS) | $250 a day, up to $150,000 per plan year |
Disaster and other special relief
Separate announcements can move dates. “The IRS, DOL, and PBGC may announce special extensions of time under certain circumstances, such as extensions for Presidentially-declared disasters”. If you rely on one, the form has a box for it; check the agencies’ announcements for the year in question.
If you miss the date
A late filing exposes the plan administrator to the penalties described on the Form 5500 instructions page, including “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 Delinquent Filer Voluntary Compliance (DFVC) Program is the reduced-penalty route for late Title I filings.
Common mistakes
- Filing Form 5558 after the normal due date. It must be filed on or before it.
- Counting the extension from the extended income tax date rather than the plan year.
- Treating a Form 5500 extension as an extension for the PBGC premium filing.
Related: the Form 5500 instructions, Form 5500-SF versus the full Form 5500, Form 5500-EZ for one-participant plans, and 401(k) fees by plan size.
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 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
- IRS Instructions for Form 5500-EZ (2025): https://www.irs.gov/pub/irs-pdf/i5500ez.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.