Form 5500-SF: Filing the Short Form Annual Return via EFAST2

Form 5500-SF is the short annual return that small employee benefit plans file electronically each year with the Department of Labor, IRS, and Pension Benefit Guaranty Corporation. A plan can use it instead of the full Form 5500 if it had fewer than 100 participants at the start of the plan year and its assets are limited to easy-to-value investments, along with several other conditions. Filings go through EFAST2, and the return is due on the last day of the seventh month after the plan year ends.¹

Which Plans Can Use the Short Form

The 2025 instructions list eight conditions, and every one has to be met:²

Fewer than 100 participants at the start of the plan year. A plan that filed as a small plan the previous year can still use the short form with up to 120 participants at the start of the current year, so plans hovering near the threshold don’t switch forms every time headcount shifts.
No employer securities held at any point during the year.
100% of assets invested in items that are easy to value: mutual fund shares, publicly traded securities held by a registered broker-dealer, insurance or bank investment contracts valued at least annually, cash, and participant loans.
The plan qualifies for a waiver of the independent accountant audit under 29 CFR 2520.104-46, and not solely by relying on enhanced bonding.
Not a multiemployer plan.
Not a multiple-employer welfare arrangement required to file Form M-1.
Not a pooled employer plan.
Not part of a DCG reporting arrangement.

Both pension plans (401(k)s, profit-sharing, defined benefit) and welfare benefit plans (health, life insurance) can file on the SF as long as they clear all eight items.²

The Audit Waiver

The audit waiver is what makes the short form possible for most small pension plans. Under 29 CFR 2520.104-46, a small pension plan can skip the annual independent audit if at least 95% of its assets are “qualifying plan assets” held by regulated financial institutions.³ If less than 95% qualifies, the plan can still get the waiver, but only if everyone who handles those non-qualifying assets carries a fidelity bond covering at least 100% of their value.⁴ A plan that needs enhanced bonding to qualify for the waiver cannot use Form 5500-SF; it has to file the full Form 5500.

The waiver comes with disclosure obligations. The plan’s summary annual report must list each institution holding qualifying assets and the amount held, and if more than 5% of assets are non-qualifying, the report must name the surety company. Participants can request the underlying statements and bond documentation.³

How Participants Are Counted

Because the participant count decides whether the plan is small enough, the definition matters. For pension plans, participants include:⁵

Active employees earning credited service, including those merely eligible to make 401(k) deferrals and nonvested employees still accruing.
Retirees and separated employees receiving benefits, unless an insurer has made an irrevocable commitment to pay the full benefit.
Separated employees entitled to future benefits who haven’t started collecting, with the same insurer exception.
Deceased participants whose beneficiaries are receiving or will receive benefits, again subject to the insurer exception.

Former employees who took a full cash-out or broke service and forfeited their entire nonvested balance are not counted. For welfare plans, the count includes former employees on COBRA continuation coverage, but their dependents are not counted separately.

When You Need Form 5500-EZ Instead

One-participant plans and foreign plans have their own form: the 5500-EZ. Since January 2021, these plans can no longer substitute the 5500-SF. If you’re a sole proprietor with no employees other than a spouse, or your plan covers only partners and their spouses, the EZ is the correct form.⁶

A one-participant plan doesn’t need to file at all if the combined assets of all one-participant plans the sponsor maintains are $250,000 or less at the end of the plan year. Once assets cross that line, filing is required. And regardless of asset value, a Form 5500-EZ is always required in the plan’s final year.⁷

What You’ll Need to Complete It

Pull the plan’s identifying information first: the sponsor’s legal name, nine-digit EIN, mailing address, the three-digit plan number, and the plan’s original effective date. The EIN and plan number combine into a 12-digit identifier all three agencies use to track the plan across years, so they must match your prior filings exactly.⁸

The financial section is the heart of the return. Report total assets and liabilities at both the beginning and end of the plan year, plus net assets. Income figures include employer contributions, participant contributions, and investment gains or losses. Expenses cover benefit payments, administrative costs, and other outflows. You’ll also select plan characteristic codes that describe the type of benefits the plan provides.

Small defined benefit plans filing on the SF still owe actuarial reporting. Single-employer defined benefit pension plans must attach Schedule SB, prepared by the plan’s enrolled actuary. Money purchase plans currently amortizing a funding waiver attach Schedule MB instead, completing at minimum lines 3, 9, and 10.²

Filing Through EFAST2

Every Form 5500-SF filing goes through EFAST2, the Department of Labor’s electronic system. Paper filing is not an option.⁹

Anyone who will sign the filing needs EFAST2 credentials first. Register on the EFAST2 website, select the “Filing Signer” user type, set up a security question, and wait for the confirmation email (usually within about five minutes). The email contains a link to complete registration, accept the signature agreement, and create a password. Your PIN then serves as your electronic signature.¹⁰

Once the form is entered and signed, submission returns one of three statuses: Accepted, Accepted with Warnings, or Rejected. Download the filing receipt right away as proof of compliance. A rejected filing needs to be corrected and resubmitted promptly to avoid penalty exposure.

Deadline and Extension

Form 5500-SF is due on the last day of the seventh month after the plan year ends. For calendar-year plans that means July 31.¹

To get more time, file Form 5558 before the original due date. It buys a one-time extension of two and a half months, pushing a calendar-year plan’s deadline to October 15. Form 5558 cannot be filed after the original deadline has passed; at that point the filing is already late.⁹

Amending a Filing

If you find an error after your return is accepted, submit an amended return through EFAST2. Check the “Amended Return/Report” box in Part I and resubmit the entire form with all schedules and attachments. The system treats the amended filing as a complete replacement.⁹ Before resubmitting, use the DOL’s Form Version Selection Tool to confirm you’re on the correct version for the plan year you’re amending.

Filing a Final Return

When a plan terminates and all assets have been distributed to participants or transferred to another plan, file one last Form 5500-SF with the “Final Return/Report” box checked in Part I. The final return covers the plan year that ends on the date the last assets were distributed.²

You cannot check the “Final Return/Report” box if the plan still holds any assets or reports any participants at year-end. If the plan has terminated but distributions aren’t finished, keep filing annual returns until the last dollar is out. A welfare plan faces the same rule: it can’t file a final return while it still owes benefits on claims incurred before the termination date.²

What Happens If You File Late

Late filings can trigger penalties from two agencies at the same time. The IRS imposes $250 per day for each day a required return remains unfiled, up to $150,000 per return, unless the plan can demonstrate reasonable cause.¹¹ The Department of Labor has separate penalty authority under ERISA with inflation-adjusted daily rates, published annually.¹² The two streams run independently.

The Delinquent Filer Voluntary Compliance Program

If you’ve missed a deadline and haven’t been contacted by the DOL yet, the Delinquent Filer Voluntary Compliance Program (DFVCP) offers sharply reduced penalties. For small plans, the reduced penalty is $10 per day, capped at $750 per late filing and $1,500 per plan across all late filings. Plans sponsored by 501(c)(3) tax-exempt organizations have a $750-per-plan cap.¹³

Participation is a two-step process. File the late Form 5500-SF through EFAST2 with the “DFVCP” box in Part I checked, then use the DFVC Program Calculator on the DOL website to determine the penalty and submit payment through pay.gov. The calculator accepts ACH, credit cards, and debit cards. Filings submitted to EFAST2 can take up to 24 hours to appear in the calculator system.¹⁴

Two limits are worth knowing. By using the program, you waive your right to challenge the penalty amount. And the DFVCP resolves only DOL penalties; any IRS penalty you also owe is separate.

Records to Keep

ERISA Section 107 requires plan administrators to keep records supporting each Form 5500-SF filing for at least six years from the filing date. That includes the filed return, all schedules and attachments, financial institution statements, nondiscrimination test results, participant communications, and evidence of the plan’s fidelity bond. When you file an amended return, the six-year clock restarts from the amended filing date.

1
U.S. Department of Labor. Instructions for Form 5500-SF Short Form Annual Return/Report of Small Employee Benefit Plan
2
U.S. Department of Labor. 2025 Instructions for Form 5500-SF
3
GovInfo. 29 CFR 2520.104-46
4
U.S. Department of Labor. Frequently Asked Questions On The Small Pension Plan Audit Waiver Regulation
5
U.S. Department of Labor. Instructions for Form 5500 Annual Return/Report of Employee Benefit Plan
6
U.S. Department of Labor. Form 5500 Series
7
Internal Revenue Service. Financial Advisors – Are Assets in Your Clients One-Participant Plans More Than $250,000
8
U.S. Department of Labor. 2025 Instructions for Form 5500
9
U.S. Department of Labor. FAQs on EFAST2 Electronic Filing System
10
U.S. Department of Labor. EFAST2 Credentials FAQs
11
Office of the Law Revision Counsel. 26 USC 6652 – Failure to File Certain Information Returns
12
U.S. Department of Labor. Fact Sheet – Adjusting ERISA Civil Monetary Penalties for Inflation
13
U.S. Department of Labor. Delinquent Filer Voluntary Compliance (DFVC) Program
14
U.S. Department of Labor. DFVC Penalty Calculator