Form 5500-EZ is the annual return for a one-participant plan or a foreign plan, which is not subject to ERISA section 104(a) reporting. It goes to the IRS, on paper or through EFAST2, and in many years it does not have to be filed at all.
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.
For a late Form 5500-EZ, the clock counts the days on the IRS side and shows what the IRS relief program costs.
Two kinds of plan use it. A one-participant plan is a defined benefit pension plan or a defined contribution profit-sharing or money purchase pension plan, other than an employee stock ownership plan, and the plan must be a plan that covers only the business owner, or the owner and spouse, who own the entire business, or only the partners in a partnership and their spouses, and provides benefits to no one else. A foreign plan is a pension plan maintained outside the United States primarily for nonresident aliens. A solo 401(k) is a profit-sharing plan with a 401(k) feature, so it fits the first group.
The choice of form is not open. Under the instructions, a one-participant plan or foreign plan cannot file Form 5500 or Form 5500-SF instead, even if it filed one of them before. A plan that hires its first employee who becomes a participant stops being a one-participant plan, and from then on the ordinary rules apply.
Under the 2025 Instructions for Form 5500-EZ, Who Must File and Who Does Not Have To File, page 2, a one-participant plan does not file for a plan year in which the plan's assets plus the assets of every other one-participant plan the employer maintains, measured at the end of the plan year, comes to $250,000 or less, unless it is the final plan year.
Three things follow from that sentence, and each is commonly got wrong.
The test is per year. A plan that was over the line last year and filed, and is at or under it this year, does not file this year. Filing once does not start a filing habit the law requires.
The assets are combined. if the combined total is over the threshold, every one of the employer's one-participant plans files, including a plan holding less on its own. An owner with a solo 401(k) and a defined benefit plan adds the two together.
The measure is year-end assets, as reported on the form, not contributions and not the peak during the year.
Under the same instructions, a one-participant plan files for its final plan year, the year in which distribution of all plan assets is completed, whatever its assets. A plan that never crossed the line, and so never filed, still files for the year it pays everything out. This is the return most often skipped, because the plan is closed by the time it is due.
There are two ways: on paper with the IRS, or electronically through EFAST2. For many filers the choice is made for them.
Under the 2025 Instructions for Form 5500-EZ, How To File, page 2, for plan years beginning on or after 1 January 2025, a filer required to file at least 10 returns of any type with the IRS, counting information returns such as Forms W-2 and 1099 and income, employment and excise tax returns, during the calendar year that includes the first day of the plan year must file Form 5500-EZ electronically through EFAST2.
Ten returns comes up quickly. A small business with a few employees issuing W-2s, plus 1099s to contractors, plus its own income tax return, is likely past it. Count every return type the instructions list before deciding paper is still allowed. IRS, About Form 5500-EZ
Under the 2025 Instructions for Form 5500-EZ, When To File, page 3, Form 5500-EZ is due on the last day of the seventh calendar month after the end of the plan year.
Under the 2025 Instructions for Form 5500-EZ, Extension of Time To File, page 4, a one-time extension of up to two and a half months is available by filing Form 5558 on or before the normal due date, and the Form 5558 is not attached to the return. For a calendar year plan the dates are the same as for Form 5500, 31 July and 15 October. The due dates page covers other plan years, and the extensions page covers Form 5558. IRS, About Form 5558
Under the 2025 Instructions for Form 5500-EZ, page 3, the information must be made available to the public, but information for a one-participant plan or a foreign plan is not published on the internet, whether it was filed through EFAST2 or on paper.
Late one-participant plans cannot use the Department of Labor's DFVCP program. The IRS program is Revenue Procedure 2015-32, at $500 per delinquent return up to $1,500 per submission, and separate submissions are required for separate plans, so $1,500 is the ceiling for one plan, on paper. The late Form 5500-EZ page sets out the steps, and the clock counts the days on the IRS side.
Only for a plan year in which the combined year-end assets of all the employer's one-participant plans are over $250,000, and always for the final plan year. At or under that amount, no return is due for that year.
Not because of last year. The test is run again each plan year on year-end assets. If the combined total is $250,000 or less and it is not the final year, no return is due for that year.
Yes, through EFAST2, or on paper with the IRS. For plan years beginning on or after 1 January 2025, a filer that must file at least 10 returns of any type with the IRS in the calendar year has to use EFAST2.
On the last day of the seventh calendar month after the end of the plan year. A Form 5558 filed by that date extends it once, by up to two and a half months.
Late one-participant plans use the IRS program in Revenue Procedure 2015-32, which costs $500 per delinquent return up to $1,500 per submission, and separate submissions are required for separate plans, so $1,500 is the ceiling for one plan. It is done on paper, and DFVCP is not available.
Figures on this page were last verified against these sources on 2 November 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.
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.
Solo plan returns get missed in the years the asset test flips. A call with our engineers is about catching those: