Form 5500 deadlines in 2026 IRS disaster areas

Form 5500 filers in an IRS disaster area get the IRS postponement, and the Department of Labor and PBGC allow the same one. This page lists every release open on 15 October 2026, the areas each one covers and the date it moves deadlines to.

This page is about the ERISA Form 5500, the annual return/report that employee benefit plans file with the Department of Labor and the IRS through EFAST2. The same number is used for an unrelated US Navy supply form, and other countries use different form numbers for their pension returns; none of that applies here.

Run the clock for the plan as usual. It does not know the plan's county, so check the list below before you treat a late card as late.

Run the Form 5500 Rescue Clock

The rule in two sentences

An IRS disaster postponement covers the Form 5500 series. The IRS lists it among the acts it can postpone, and the Department of Labor and PBGC follow whatever the IRS allows.

Under Rev. Proc. 2018-58, section 8, item 40: "Whatever postponement of the Form 5500 series filing due date is permitted by the IRS under section 7508A will also be permitted by the Department of Labor and PBGC for similarly situated plan administrators and direct filing entities."

None of the 2026 releases names Form 5500. Each one postpones the time-sensitive acts listed in Rev. Proc. 2018-58, and that list is where Form 5500 sits. So the release text reads like an income tax notice, which makes it easy to skim past.

Who counts as affected

The releases cover individuals who live, and businesses (including tax-exempt organizations) whose principal place of business is located, in the covered disaster area. Two further groups get the same relief. The first is anyone whose records sit in the area: "Taxpayers not in the covered disaster area, but whose records necessary to meet a deadline listed in Treas. Reg. § 301.7508A-1(c) are in the covered disaster area, are also entitled to relief." The second comes from Rev. Proc. 2018-58 itself, and it is the one a TPA should read twice:

Under Rev. Proc. 2018-58, section 8, item 40: "Taxpayers who are unable on a timely basis to obtain information necessary for completing the forms from a bank, insurance company, or any other service provider because such service provider’s operations are located in a covered disaster area will be treated as affected taxpayers."

A TPA, recordkeeper or bank is a service provider. When its office is in a covered county, that sentence can reach plans whose sponsors are nowhere near the storm. Whether it reaches a given plan turns on whether the information really could not be had on time, and that is a judgment for the plan's own adviser.

Which date moves, and which does not

A release moves the deadlines that fall inside its window, and nothing else. For a calendar-year plan the two dates that matter are 31 July and 15 October. A window that opens on or before 31 July moves both. A window that opens after it moves only the 15 October date, which helps a plan with Form 5558 on file and does nothing for one without it.

Under IRS release MI-2026-02, deadlines falling on or after 10 April 2026 and before 2 November 2026 move to 2 November 2026 in 37 Michigan counties.

Under IRS release FL-2026-07, deadlines falling on or after 9 October 2026 and before 8 February 2027 move to 8 February 2027 in 27 Florida counties.

How the return shows it

A filer using the postponement marks it on the return. In the 2025 Instructions for Form 5500, Other Extensions of Time, page 5: "If you are relying on one of these announced special extensions, check the appropriate box on Form 5500, Part I, line D, and enter a description of the announced authority for the extension." A Form 5500-EZ has the same box on Part I, line B.

Every release open on 15 October 2026

Coverage goes by county, parish, island or tribal area, never by whole state. Find the plan administrator's county below, then open the release and check it there before relying on it.

Moved to 2 November 2026

Louisiana, 9 parishes, release LA-2026-02. Deadlines falling on or after 17 June 2026 and before 2 November 2026 move to 2 November 2026. Covered, as the release lists them: Avoyelles, East Feliciana, Lafourche, Pointe Coupee, St. Charles, St. Landry, St. Tammany, Terrebonne, Winn.

Michigan, 37 counties, release MI-2026-02. Deadlines falling on or after 10 April 2026 and before 2 November 2026 move to 2 November 2026. Covered, as the release lists them: Alcona, Allegan, Alpena, Antrim, Barry, Benzie, Charlevoix, Cheboygan, Crawford, Eaton, Emmet, Grand Traverse, Gratiot, Iosco, Iron, Kalamazoo, Kalkaska, Lake, Manistee, Marquette, Mecosta, Menominee, Missaukee, Montcalm, Montmorency, Muskegon, Newaygo, Oceana, Ogemaw, Osceola, Oscoda, Presque Isle, Roscommon, Saginaw, Tuscola, Washtenaw, Wexford.

Mississippi, 5 counties, release MS-2026-02. Deadlines falling on or after 6 May 2026 and before 2 November 2026 move to 2 November 2026. Covered, as the release lists them: Franklin, Lamar, Lawrence, Lincoln, Wilkinson.

Northern Mariana Islands (Super Typhoon Sinlaku), release NMI-2026-01. Deadlines falling on or after 11 April 2026 and before 2 November 2026 move to 2 November 2026. Covered, as the release lists them: Northern Islands, Rota, Saipan, Tinian.

Wisconsin, 21 counties and the Oneida Indian Reservation, release WI-2026-02. Deadlines falling on or after 13 April 2026 and before 2 November 2026 move to 2 November 2026. Covered, as the release lists them: Bayfield, Brown, Buffalo, Iowa, Jackson, Jefferson, Juneau, Kenosha, Kewaunee, Manitowoc, Marathon, Milwaukee, Outagamie, Racine, Rock, Sauk, Vernon, Washington, Waukesha, Waupaca, Winnebago, Oneida Indian Reservation.

Moved to 7 January 2027

Knox County, Nebraska, release NE-2026-08. Deadlines falling on or after 9 September 2026 and before 7 January 2027 move to 7 January 2027. Covered, as the release lists them: Knox County.

Moved to 1 February 2027

Hawaii County, Hawaii, release HI-2026-03. Deadlines falling on or after 22 May 2026 and before 1 February 2027 move to 1 February 2027. Covered, as the release lists them: Hawaii County.

Indiana, 30 counties, release IN-2026-01. Deadlines falling on or after 11 August 2026 and before 1 February 2027 move to 1 February 2027. Covered, as the release lists them: Carroll, Cass, Dearborn, Decatur, Delaware, Fayette, Franklin, Grant, Hamilton, Hancock, Henry, Lake, LaPorte, Madison, Marion, Morgan, Parke, Porter, Pulaski, Randolph, Rush, Starke, Tipton, Union, Vermillion, Warren, Wayne, Fountain, Pike, Putnam.

Mississippi, 8 counties (Tropical Storm Arthur), release MS-2026-03. Deadlines falling on or after 18 June 2026 and before 1 February 2027 move to 1 February 2027. Covered, as the release lists them: Covington, George, Greene, Hancock, Harrison, Pearl River, Stone, Wayne. The release also carries an IRS update note dated 21 August 2026 about payroll deadlines; read it on the release page.

Nebraska, 10 counties (March wildfires), release NE-2026-03. Deadlines falling on or after 12 March 2026 and before 1 February 2027 move to 1 February 2027. Covered, as the release lists them: Morrill, Garden, Arthur, Keith, Grant, Lincoln, Dawson, Frontier, Saunders, Red Willow.

Custer County, Nebraska, release NE-2026-04. Deadlines falling on or after 22 April 2026 and before 1 February 2027 move to 1 February 2027. Covered, as the release lists them: Custer County.

Nebraska, 9 counties (severe storms), release NE-2026-05. Deadlines falling on or after 15 May 2026 and before 1 February 2027 move to 1 February 2027. Covered, as the release lists them: Buffalo, Fillmore, Gage, Jefferson, Nemaha, Richardson, Thayer, Thurston, Howard.

Dawes County, Nebraska, release NE-2026-06. Deadlines falling on or after 16 May 2026 and before 1 February 2027 move to 1 February 2027. Covered, as the release lists them: Dawes County.

Sioux County, Nebraska, release NE-2026-07. Deadlines falling on or after 9 June 2026 and before 1 February 2027 move to 1 February 2027. Covered, as the release lists them: Sioux County.

Rota, Saipan and Tinian (Super Typhoon Bavi), release NMI-2026-02. Deadlines falling on or after 4 July 2026 and before 1 February 2027 move to 1 February 2027. Covered, as the release lists them: Rota, Saipan, Tinian. The release also carries an IRS update note dated 21 August 2026 about payroll deadlines; read it on the release page.

Ohio, 7 counties, release OH-2026-02. Deadlines falling on or after 10 August 2026 and before 1 February 2027 move to 1 February 2027. Covered, as the release lists them: Clermont, Franklin, Hamilton, Licking, Morgan, Muskingum, Perry.

Oglala Sioux Tribe, South Dakota, release SD-2026-02. Deadlines falling on or after 2 June 2026 and before 1 February 2027 move to 1 February 2027. Covered, as the release lists them: Oglala Sioux Tribe. The IRS list page shows this release as SD-2026-05.

Douglas County, Washington, release WA-2026-02. Deadlines falling on or after 31 July 2026 and before 1 February 2027 move to 1 February 2027. Covered, as the release lists them: Douglas County.

Washington, 6 counties and 3 tribal areas, release WA-2026-03. Deadlines falling on or after 31 July 2026 and before 1 February 2027 move to 1 February 2027. Covered, as the release lists them: Chelan, Ferry, Okanogan, Spokane, Stevens, Yakima, Confederated Tribes and Bands of the Yakama Nation, Confederated Tribes of the Colville Reservation, Spokane Tribe of Indians.

Wisconsin, 4 counties, release WI-2026-03. Deadlines falling on or after 27 July 2026 and before 1 February 2027 move to 1 February 2027. Covered, as the release lists them: Forest, Outagamie, Vilas, Winnebago.

West Virginia, 4 counties, release WV-2026-01. Deadlines falling on or after 21 July 2026 and before 1 February 2027 move to 1 February 2027. Covered, as the release lists them: Lewis, Pleasants, Ritchie, Upshur. The release also carries an IRS update note dated 21 August 2026 about payroll deadlines; read it on the release page.

Moved to 4 February 2027

Alabama, 40 counties, release AL-2026-01. Deadlines falling on or after 7 October 2026 and before 4 February 2027 move to 4 February 2027. Covered, as the release lists them: Autauga, Baldwin, Barbour, Bibb, Bullock, Butler, Chambers, Chilton, Clarke, Choctaw, Coffee, Conecuh, Coosa, Covington, Crenshaw, Dale, Dallas, Elmore, Escambia, Geneva, Greene, Hale, Henry, Houston, Lee, Lowndes, Macon, Marengo, Mobile, Monroe, Montgomery, Perry, Pickens, Pike, Russell, Sumter, Tallapoosa, Tuscaloosa, Washington, Wilcox.

Guam, release GU-2026-01. Deadlines falling on or after 4 July 2026 and before 4 February 2027 move to 4 February 2027. Covered, as the release lists them: territory of Guam.

Pueblo of Zuni, New Mexico, release NM-2026-03. Deadlines falling on or after 16 July 2026 and before 4 February 2027 move to 4 February 2027. Covered, as the release lists them: Pueblo of Zuni.

West Virginia, 3 counties, release WV-2026-02. Deadlines falling on or after 14 August 2026 and before 4 February 2027 move to 4 February 2027. Covered, as the release lists them: Fayette, Harrison, Kanawha.

Moved to 8 February 2027

Florida, 27 counties, release FL-2026-07. Deadlines falling on or after 9 October 2026 and before 8 February 2027 move to 8 February 2027. Covered, as the release lists them: Baker, Bay, Calhoun, Citrus, Columbia, Dixie, Escambia, Franklin, Gadsden, Gilchrist, Gulf, Hamilton, Holmes, Jackson, Jefferson, Lafayette, Leon, Levy, Liberty, Madison, Okaloosa, Santa Rosa, Suwannee, Taylor, Wakulla, Walton, Washington.

Read off the IRS list of disaster relief releases, each release opened on 15 October 2026. New releases arrive through the autumn, and the IRS list is the current one.

What the clock does with this

Nothing, on purpose. The clock asks for a plan year end, not an address, so it cannot tell whether a plan is covered. A covered plan still shows as late on its card. If the plan administrator is in one of the areas above, read that card with the postponed date in mind, file by it, and tick the box. Pasting a plan book still works: run the whole book, then pull out the plans whose administrators sit in a covered county.

Questions

Does an IRS disaster postponement apply to Form 5500?

Yes, for affected filers. Rev. Proc. 2018-58, section 8, item 40 lists the Form 5500 series among the acts the IRS can postpone, and the Department of Labor and PBGC allow the same postponement for similarly situated plan administrators.

Which box do I check on Form 5500 for a disaster extension?

The special extension box on Part I, line D, with a description of the announced authority. On Form 5500-EZ it is Part I, line B.

Does a TPA's location count?

It can. Rev. Proc. 2018-58 treats as affected a filer who cannot get the information it needs on time from a bank, insurer or other service provider whose operations are in a covered area.

Does the clock apply disaster postponements?

No. It does not ask where a plan is, so a covered plan still shows as late. Check the list on this page first.

Sources

  1. IRS, tax relief in disaster situations: https://www.irs.gov/newsroom/tax-relief-in-disaster-situations
  2. Rev. Proc. 2018-58: https://www.irs.gov/pub/irs-drop/rp-18-58.pdf
  3. Department of Labor, Form 5500 reporting and filing: https://www.dol.gov/agencies/ebsa/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500
  4. IRS Form 5500 corner: https://www.irs.gov/retirement-plans/form-5500-corner

Figures on this page were last verified against these sources on 15 October 2026. Where this page and the Department of Labor or the IRS disagree, the agency is right and this page is wrong; tell us at hello@02launch.com.

Who made this

02Launch is an AI engineering firm out of Google and Microsoft. We built the Form 5500 Rescue Clock because the late Form 5500 decision sits across two agencies and nobody had put it in one place for a plan book.

What a call with our engineers is for, when the book has plans in more than one county:

Speak with our team

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