To file Form 5500-SF, confirm your small benefit plan meets the eligibility rules, collect the plan’s identifying and financial data for the year, complete the form electronically through the Department of Labor’s EFAST2 system, and submit it with electronic signatures from both the plan administrator and the plan sponsor by the last day of the seventh month after the plan year ends. For a calendar-year plan, that deadline is July 31. The form is filed jointly with the DOL, the IRS, and the Pension Benefit Guaranty Corporation, and paper submissions are not accepted.
Confirm Your Plan Qualifies for the Short Form
Form 5500-SF is only for small plans that meet three conditions. Miss any one and you file the full Form 5500 instead.
- Fewer than 100 participants at the beginning of the plan year, counting active employees, retirees drawing benefits, and separated employees with vested balances.
- One hundred percent of plan assets held in investments with a readily determinable fair market value: mutual fund shares, assets at banks or similar institutions, insurance and annuity contracts, assets at registered broker-dealers, and participant-directed accounts for which a regulated financial institution provides at least an annual statement.
- Qualification for the independent audit waiver under 29 CFR 2520.104-46. At least 95 percent of assets must be qualifying plan assets, or anyone handling non-qualifying assets must be bonded for at least their value. The summary annual report has to name the financial institutions holding assets and any bond surety.
Plans that hold employer securities, file Form M-1, operate as multiemployer plans, or are pooled employer plans cannot use the short form regardless of size.
One boundary worth naming: a plan covering only the business owner, partners, and their spouses, or a foreign plan, cannot use Form 5500-SF. Those file Form 5500-EZ, and only when total plan assets exceed $250,000 at year-end or the plan is in its final year. If your plan covers any non-owner employees, Form 5500-EZ is not an option.
A special transition rule applies when your participant count drifts. A plan that filed as small last year and now has between 80 and 120 participants can continue filing as a small plan, and therefore keep using Form 5500-SF, until the count exceeds 120. Once it hits 121, you move to the full Form 5500 and an independent audit. If the number later falls, you can’t return to small-plan status until it drops below 80.
Gather Everything Before You Log In
EFAST2 will not let you save partial data indefinitely, and missing pieces stall the whole filing. Pull the following together first:
- The plan sponsor’s legal name, Employer Identification Number, and business address.
- The three-digit plan number assigned to this specific plan within the sponsor’s organization. First plans are typically 001, second plans 002, and so on.
- The plan administrator’s name, EIN, and contact information, if that’s someone other than the sponsor.
- Participant counts at both the beginning and end of the plan year, split among active participants, retired or separated participants receiving benefits, and separated participants with deferred vested benefits.
- Total plan assets, liabilities, and net assets at the start and end of the year; total contributions received; total benefit payments and distributions made; and total administrative expenses paid.
- The benefit plan feature codes describing the type of plan (401(k), profit-sharing, defined benefit, health, and so on) and its features.
A single-employer defined benefit pension plan also needs Schedule SB with actuarial information. Money purchase plans amortizing a funding waiver need Schedule MB. Multiple-employer pension plans need Schedule MEP.
Complete the Form Section by Section
The form moves through plan identification, participant data, financials, and compliance questions in that order.
Plan Identification
Lines 1 through 4 capture the sponsor’s name, EIN, and address, plus the three-digit plan number and the plan year dates. Calendar-year plans run January 1 through December 31. A short plan year, from a mid-year plan establishment or termination, uses the actual start and end dates. Check the box for a first-year, final, or amended filing when it applies. The final-return box matters at plan termination because it tells the agencies not to expect further filings.
Basic Plan Information
Lines 5 through 8 identify the administrator, list the applicable benefit codes, and report participant counts. The beginning-of-year count determines whether you qualify as small, so verify it carefully. If it reaches 100 and the 80-120 rule doesn’t save you, the plan needs the full Form 5500 with an audit.
Financial Information
Lines 9 through 15 cover total assets, liabilities, and net assets at each end of the year, then break out income (employer contributions, employee contributions, investment earnings) and expenses (benefit payments, corrective distributions, administrative costs). Report any participant loans outstanding at year-end separately. The numbers should match the plan’s books and financial institution statements. Discrepancies between the return and the recordkeeper’s numbers are the most common reason a filing gets flagged.
Compliance Questions
The remaining lines ask whether the plan had a blackout period, whether late contributions occurred, whether the plan received a favorable IRS determination letter, and whether an amendment was adopted during the year. A “yes” on certain questions can trigger additional reporting or draw closer DOL review, so answer with care and documentation.
File Through EFAST2
All Form 5500-SF filings go through the EFAST2 system at efast.dol.gov, either through the DOL’s web-based IFILE tool or through approved third-party software.
Getting Your Credentials
The plan administrator and the plan sponsor (or their authorized representatives) each need EFAST2 filing credentials. As of January 2023, new users must create a Login.gov account to access the system; the older EFAST2 User ID and password no longer work. Each signer registers once and receives a personal User ID and PIN that functions as their electronic signature. Credentials are tied to the person, not the plan, so someone overseeing multiple plans only needs one set.
Submitting the Return
Once the data is entered, EFAST2 runs a validation check for formatting errors and missing fields. Fix anything flagged. Then both the administrator and the sponsor apply their electronic signatures. The system returns one of four statuses: Accepted, Accepted with Warnings, Under Review, or Rejected. Accepted with Warnings means the filing is complete but has non-critical issues worth reviewing. Rejected means the filing did not go through and must be corrected and resubmitted.
Meet the Deadline, or Extend It
Form 5500-SF is due by the last day of the seventh month after the plan year ends.1Internal Revenue Service. Form 5500 Corner For calendar-year plans, that’s July 31. A fiscal-year plan ending June 30 would have a January 31 deadline.
For more time, file IRS Form 5558 to request a one-time extension of up to two and a half months.2Internal Revenue Service. Form 5558 Reminders For a calendar-year plan, that moves the deadline to October 15. The extension is automatically approved if Form 5558 is filed on or before the original due date and the requested date is no later than two and a half months after that deadline.3Internal Revenue Service. IRS Form 5558 – Application for Extension of Time To File Certain Employee Plan Returns Form 5558 is a paper form and cannot be filed electronically, so mail it well before the original deadline.
When a plan terminates mid-year, you still file a Form 5500-SF for the short plan year. The deadline is seven months after the plan year ended (the date all assets were distributed), and you check the final-return box.
What Happens If You File Late
Late filings trigger penalties from two agencies, and the penalties stack.
Under ERISA Section 502(c)(2), the DOL can assess a civil penalty of up to $2,670 per day for each day a required annual report is overdue.4U.S. Department of Labor. Fact Sheet – Adjusting ERISA Civil Monetary Penalties for Inflation The amount is inflation-adjusted and has climbed over time. The penalty runs from the original due date until the DOL receives a satisfactory filing.5eCFR. 29 CFR 2560.502c-2 – Civil Penalties Under Section 502(c)(2)
The IRS adds its own penalty under IRC Section 6652(e): $250 per day, up to a maximum of $150,000 per return.6Office of the Law Revision Counsel. 26 USC 6652 – Failure To File Certain Information Returns, Registration Statements, Etc. It applies unless the filer shows reasonable cause. Incomplete filings that aren’t corrected promptly can trigger it as well.
If you’ve already missed a deadline and the DOL hasn’t contacted you yet, the Delinquent Filer Voluntary Compliance Program cuts the penalty sharply. For small plans, the rate drops to $10 per day, capped at $750 per late filing and $1,500 per plan.7U.S. Department of Labor. Delinquent Filer Voluntary Compliance Program Small plans sponsored by a 501(c)(3) organization get an even lower per-plan cap of $750. Once the DOL sends a notice of late filing, DFVCP is off the table and the full penalty schedule applies, so move quickly if you know a filing is overdue.