Form 5500 is the annual return/report that an employee benefit plan covered by ERISA files with the Department of Labor, and the same filing serves the IRS and the PBGC. It has a fixed due date, it is filed electronically, and once it is in, anyone can read it.
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.
If a plan's Form 5500 is late, the clock gives the missed due date, the days late on each agency's count, and the DFVCP fee.
Under Code section 6058(a) and ERISA sections 104 and 4065, as set out on page 1 of the 2025 Instructions for Form 5500, any administrator or sponsor of an employee benefit plan subject to ERISA must file information about each benefit plan every year.
One filing serves three agencies: the Internal Revenue Service, the Department of Labor and the Pension Benefit Guaranty Corporation. Each uses it for its own purpose. The Department of Labor checks that the plan is run and reported as ERISA requires. The IRS checks the plan's tax-qualified status. The PBGC uses the defined benefit data. A plan files once, through one system, and all three read the same return.
| Form | Who files it | Where it goes |
|---|---|---|
| Form 5500 | Large plans, and small plans that do not qualify for the short form | EFAST2 only |
| Form 5500-SF | Small plans that meet every short form condition | EFAST2 only |
| Form 5500-EZ | One-participant plans and foreign plans | The IRS on paper, or EFAST2 |
A small plan has fewer than 100 participants as of the beginning of the plan year. The who must file page works through which version applies to a given plan, including the plans that file nothing, and the Form 5500-EZ page covers the one-participant case.
The main form is a few pages of identifying details and yes or no questions. The detail sits in schedules: insurance contracts on Schedule A, service providers on Schedule C, financial statements on Schedule H or Schedule I, actuarial data on Schedule SB or MB, and more. Which ones a plan attaches depends on its type and size. The schedules page has the full table.
Under 29 CFR 2520.104a-5(a)(2), the return is due on the last day of the seventh calendar month after the plan year ends.
For a plan whose year matches the calendar that is 31 July, and a Form 5558 filed by then adds two and a half months, to 15 October. Those two dates are for calendar year plans only. A plan year ending 30 June is due at the end of January. The due dates page lists every plan year end, and the extensions page covers Form 5558.
Under 29 CFR 2520.104a-2(a), a Form 5500 or Form 5500-SF is filed electronically through EFAST2, and a paper Form 5500 cannot be mailed or delivered. Filing software and service providers submit through the same system. Form 5500-EZ is the exception and can still go on paper.
Under ERISA section 502(c)(2), the Department of Labor may assess up to $2,739 a day for 2026, as indexed at 29 CFR 2575.3 and the Department of Labor's annual adjustment table at 90 FR 1854.
The IRS runs its own count. Under 26 U.S.C. 6652(e), the penalty is $250 a day up to $150,000 for returns required to be filed after 31 December 2019. The two counts do not start or stop in the same way, which is why the penalties page treats them separately. Most late Form 5500 filers can cut the Department of Labor side to a capped fee through the DFVCP program.
Under the 2025 Instructions for Form 5500, line 2b, page 17, the Form 5500 is open to public inspection, and its contents are public information that may be published on the internet.
That is why so many searches for Form 5500 are lookups of a particular company's plan. EFAST2 has a public search by plan or sponsor name. EFAST2 It also means a missing year is visible to anyone who checks, including the agencies.
The administrator or sponsor of an employee benefit plan covered by ERISA, for each plan, every year. Some plans are exempt, including small unfunded or fully insured welfare plans, governmental plans and most church plans.
Both, through one filing. Form 5500 and Form 5500-SF go to EFAST2, the Department of Labor's electronic system, and the same return serves the IRS and the PBGC. Form 5500-EZ can go to the IRS on paper or through EFAST2.
On the last day of the seventh calendar month after the plan year ends. For a calendar year plan that is 31 July, or 15 October with a timely Form 5558. Other plan years have other dates.
Yes. Under the instructions, the Form 5500 is open to public inspection, and its contents are public information that may be published on the internet. Filings can be searched by plan or sponsor name on EFAST2.
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.
With more than a handful of plans, the form is the easy part and the calendar is the hard part. A call with our engineers is about the calendar: