Form 5500-EZ: Who Files, Deadlines, and Penalty Relief

Form 5500-EZ is the annual IRS return for a one-participant retirement plan, and you must file it for any plan year in which the plan’s total assets exceed $250,000 on the last day of the year, or in which the plan terminates. For a calendar-year plan, the return is due July 31 of the following year. Miss it and the penalty runs $250 per day, capped at $150,000 per return.

Who Has to File

Two things have to be true. First, the plan must be a one-participant plan, meaning it covers only the business owner (or the owner and spouse) and provides no benefits to anyone else. The business form doesn’t matter: sole proprietorship, corporation, or partnership all qualify. Second, the total assets of that plan, combined with any other one-participant plans you maintain, must exceed $250,000 at the end of the plan year.¹

If you’re at or below $250,000, you have no filing obligation for that year. The one exception is a terminating plan: when a plan ends, you file a final return regardless of the asset amount.¹

When You No Longer Qualify

The moment you hire an employee who becomes eligible for the plan, it stops being a one-participant plan. It falls under ERISA’s reporting rules, and you can no longer use Form 5500-EZ. You’d file Form 5500 or, if eligible, Form 5500-SF electronically instead.¹²

Employee Stock Ownership Plans are excluded from the one-participant definition entirely and cannot use this form.¹

Deadline and Extension

The return is due by the last day of the seventh month after the plan year ends. For calendar-year plans, that’s July 31. If the due date lands on a weekend or federal holiday, the next business day works.¹

Need more time? File Form 5558 before the original due date. The extension is automatic and runs to the 15th day of the third month after the original due date, which pushes a calendar-year plan out to October 15.³

What to Gather Before You Start

Have the plan name, the plan sponsor’s EIN, and the three-digit plan number ready. A first plan is typically 001. Identify the plan type (solo 401(k), defined benefit, profit-sharing, or money purchase pension) and its effective date.⁴p>

The financial section walks through the plan year:

Beginning and ending asset values. The ending value is what tests you against the $250,000 threshold.
Contributions made during the year, split between employer contributions and participant deferrals.
Distributions paid to participants and any rollovers out of the plan.

Your plan custodian’s year-end statement usually has everything you need.

How to File

Most filers use the Department of Labor’s EFAST2 system, which is the active platform for the 2025 plan year filed in 2026.⁵ Electronic filing is mandatory if you file at least 10 returns of any kind with the IRS in the calendar year. That count is the aggregate of everything: W-2s, 1099s, income tax returns, employment tax returns, excise tax returns.⁶

If your total IRS filings for the year are under 10, you can mail a paper Form 5500-EZ to the IRS processing center in Ogden, Utah.¹ Even so, the IRS encourages EFAST2. Electronic filing produces a confirmation of receipt, which is useful if a penalty question ever comes up later.⁷

What a Late Filing Costs

The IRS charges $250 for every day the return is late, up to $150,000 per return, plus interest. The SECURE Act of 2019 raised those numbers from the prior $25 per day and $15,000 cap.⁸

Because a one-participant plan sits outside ERISA, the Department of Labor’s civil penalties for late annual reports don’t apply here, and the DOL’s Delinquent Filer Voluntary Compliance Program is not available for Form 5500-EZ. Your exposure runs through the IRS.⁹

Fixing a Missed Filing Through IRS Penalty Relief

If you’ve missed one or more deadlines, the IRS penalty relief program reduces the cost to $500 per delinquent return, capped at $1,500 when you’re submitting three or more late returns for the same plan at once.⁸

The mechanics are specific. Submissions must be on paper by mail, not through EFAST2. Each return needs a complete Form 5500-EZ with all schedules and attachments. Check box D on Part I of the form to signal that you’re filing under the penalty relief program. If you’re using a pre-2020 version of the form that lacks that box, write “Delinquent Return Filed under Rev. Proc. 2015-32, Eligible for Penalty Relief” in red at the top of each return.¹⁰

Attach Form 14704 (the program’s transmittal schedule) to the top of the submission, with a check payable to the United States Treasury for the total fee. Write your EIN and plan number on the check. One plan per submission: if you have delinquent returns for more than one plan, mail them separately.¹⁰

You lose access to the program for any return the IRS has already assessed with a CP 283 notice. For those, you respond to the notice directly rather than using the voluntary program.¹⁰

The Final Return When You Terminate the Plan

Terminating a plan triggers a final Form 5500-EZ for the year in which all assets are distributed, no matter how small the balance. Check box A(3) on the form to indicate that all plan assets have been distributed to participants or transferred to another plan.¹

The IRS expects distributions to happen as soon as administratively feasible after the termination date, generally within one year. Beyond that, the IRS may treat the plan as ongoing, which means it has to keep meeting qualification requirements and, for defined benefit plans, minimum funding rules.¹¹

Form 8955-SSA Doesn’t Apply Here

One-participant plans aren’t subject to ERISA’s vesting standards and aren’t required to file Form 8955-SSA, the annual registration statement for separated participants with deferred vested benefits. Filing it voluntarily is allowed, but a plan covering only you and your spouse typically has no separated participants to report.¹²

1
Internal Revenue Service. Instructions for Form 5500-EZ
2
Internal Revenue Service. One-Participant 401(k) Plans
3
Internal Revenue Service. Form 5558 – Application for Extension of Time to File Certain Employee Plan Returns
4
Internal Revenue Service. About Form 5500-EZ
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U.S. Department of Labor. Welcome – EFAST2 Filing
6
Internal Revenue Service. Mandatory Electronic Filing for Certain Form 8955-SSA and 5500-EZ Returns
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U.S. Department of Labor. FAQs on EFAST2 Electronic Filing System
8
Internal Revenue Service. Penalty Relief Program for Form 5500-EZ Late Filers
9
U.S. Department of Labor. Help With The Form 5500-EZ – EFAST2 Filing
10
Internal Revenue Service. Form 5500-EZ Delinquent Filing Penalty Relief Frequently Asked Questions
11
Internal Revenue Service. Retirement Plans FAQs Regarding Plan Terminations
12
Internal Revenue Service. 2025 Instructions for Form 8955-SSA