Form 5500 due dates and filing deadline, every plan year end in one table

The rule in one line

Form 5500 is due on the last day of the seventh month after the plan year ends. That is the whole rule for a plan year that runs a full twelve months. Count seven months forward from the month the plan year closed, then go to the end of that month.

Under 29 CFR 2520.104a-5(a)(2), the Form 5500 for a calendar-year plan is due 31 July.

Form 5558 moves that date. File it with the IRS before the statutory date and the return is due later, once, with no further extension after it. The mechanics are on the extension page.

Under the 2025 Instructions for Form 5500, Extension of Time To File Using Form 5558, page 4, a Form 5558 filed on time moves the calendar-year due date to 15 October, an extension of two and a half months.

Every month-end plan year

Most plan years end on the last day of a month. Find yours in the left column. The middle column is the date the return is due with nothing filed. The right column is the date it is due if a Form 5558 went in on time.

Every row is the engine's output for that plan year end, not a date typed into this page. A date marked next year falls in the calendar year after the plan year closed. Where the due date lands on a month end the cell gives the rule rather than a number, because the last day of February is not the same date every year and the cell has to be right in every year. A plan year that ends in February reads off the February row whichever day that month ended on. The clock applies the same rule to any plan year end you give it, including one that is not a month end, and returns the dated answer for the year you enter. The table gives the date itself. When that date falls on a weekend or federal holiday in your year, the return can still go in on the next working day, and the clock works that out for the year you enter.

What "seventh month" means when the target month is shorter

Read the 31 July row. Seven months on from July is February, and February has no 31st, so the rule takes you to the last day of the month you land in. The rule says the last day of the seventh month. It does not say the same day number seven months on, which is why you never land on a day that does not exist.

That row is also the reason the middle column gives the rule and not a number. The last day of February is not the same date in every year, so the due date for a 31 July plan year moves with it. Put a year on the row and the engine returns the dated answer for that year. Read the row on its own and the answer is the rule.

The same reading answers a short plan year that ends mid-month. Go seven calendar months forward and take the end of the month you arrive in. Every Form 5500 due date is a month end for that reason, whatever day the plan year closed on.

The cutoff is a time, not a day

Under 29 CFR 2520.104a-2(a) the return is filed electronically through EFAST2, and the Department's EFAST2 guidance says the submission has to reach the system by midnight of the due date.

EFAST2 takes filings around the clock, which makes the due date the last day the return can be accepted rather than the day to start assembling it. A submission that fails validation at eleven at night on the due date is a submission that has not arrived. File the day before and keep the acknowledgment.

When the due date falls on a weekend or holiday

Under the 2025 Instructions for Form 5500, When To File, note (1), page 4, if the filing due date falls on a Saturday, Sunday or federal holiday, the return can be filed on the next day that is not a Saturday, Sunday or federal holiday.

The clock applies that to the normal due date, the Form 5558 extended date and the employer's extended tax return date, and the card shows both dates: the date itself and the day the return can be filed. Under 26 U.S.C. 7503, an IRS deadline also skips legal holidays in the District of Columbia, which adds DC Emancipation Day, 16 April, to the federal list, so a 15 April extended due date can have a later last day for the IRS than for the Department of Labor. The card shows both last days when that happens.

The next working day is a grace day, not a new due date. Under IRM 20.1.2.2.1(2), the next-day rule only decides whether a filing is on time, and a filing made after that day is late from the due date itself. For DFVCP, the Department of Labor has not said whether the fee counts from the due date itself or from the next working day, so the clock counts from the due date itself, as the IRS manual does for IRS penalties, and labels this as its reading.

Holidays come from the Office of Personnel Management's published federal holiday lists for 2011 to 2030, and for a due date outside those years the clock says so and does not guess. One reading is ours: a holiday that falls on a Saturday is kept on the Friday before and one that falls on a Sunday on the Monday after, and the clock counts that weekday as a holiday, as the federal holiday list does.

Short plan years

A plan that starts mid-year, terminates mid-year, or changes its plan year files a return for a short plan year. The seventh-month rule still applies. It runs from the day the short year ended, not from the day the full year would have ended.

Under the 2025 Instructions for Form 5500, When To File, page 4, a plan year shorter than 12 months is due the last day of the seventh calendar month after the short plan year ends, or by the extended due date.

The trap is a terminating plan. Assets get distributed, the sponsor treats the plan as finished, and nobody notices that the final return came due seven months after the last distribution. That return is the one most often found late in a plan book.

Disaster areas: when the IRS moves the date

After a disaster is declared, the IRS postpones filing deadlines for the people and businesses in the covered area. The Form 5500 series is one of the filings it can postpone, under Rev. Proc. 2018-58, section 8, item 40. The Department of Labor and PBGC go along with it. In the words of the same item: "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."

The releases cover individuals who live, and businesses (including tax-exempt organizations) whose principal place of business is located, in the covered disaster area. Records count too: "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." And Rev. Proc. 2018-58 reaches filers waiting on someone else's office: "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 filer using the postponement says so on the return. The instructions put it this way, 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." On a Form 5500-EZ the box is on Part I, line B.

Each release only moves deadlines inside its own window. One whose window opens after 31 July moves the 15 October date and leaves the 31 July date where it was. And coverage goes by county, parish or tribal area, never by whole state. The 2026 disaster areas page lists every covered area, and the release itself is the final word.

Read off the IRS list of disaster relief releases, each release opened on 15 October 2026. New releases keep coming, and the IRS list is the current one. The clock does not know where a plan is, so it applies none of these. A row it shows as late may have a later deadline if the plan is covered.

If the date has already passed, two clocks start

Miss the date and one filing carries two separate day counts. They do not start on the same day, and an extension only moves one of them.

For a plan that goes into the Department of Labor's DFVCP, the fee runs from the original due date, without regard to any extension, under 78 FR 6135, Section 3.03(b)(1).

The IRS count is the other way round. Under 26 U.S.C. 6652(e), the section 6652(e) count is determined with regard to any extension of time for filing, so a valid extension moves the day the IRS count starts. So a plan that filed Form 5558, missed the extended date anyway and then used DFVCP pays its program fee from the original date while the IRS counts from the extended one. Most guidance you will read treats the extended date as the start for both. The extension page works through what that costs, and the DFVCP page has the fee schedule.

One plan, worked through

A plan year that has not closed yet, read on the date shown. The engine returns the due date and a countdown, and stops. It prices nothing, because there is nothing late to price.

Why a TPA runs the clock instead of reading the table

The table answers one plan. A TPA holds hundreds, each with its own plan year end, some with a 5558 on file and some without, a few in a short year because of a termination. The clock takes the whole list at once and hands back one register: due date, extended date, and how far past either date each plan sits. That register is the first thing a partner asks for when a client letter arrives, and the plan book that has already run it is the one that answers the same day. If you hold one plan, the tool is free and you are done.