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The Finance Base
The Money Desk · Blog
Re:

How Can Plan Sponsors File Plan Tax Forms With the IRS?

Plan sponsors must match each filing to the plan and event: Forms 5500 generally go through EFAST2, while Form 8955-SSA is filed separately with the IRS and Form 5330 deadlines depend on the tax provision.
From TheFinanceBase Team5 min to read
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Plan sponsors do not send every employee-benefit-plan filing to the same place. File Form 5500 or 5500-SF through the Department of Labor’s EFAST2 system; file Form 8955-SSA separately with the IRS; and use the form and deadline that apply if an event creates a Form 5330 excise-tax obligation. First identify the plan and filing required, then confirm the applicable year’s instructions for filing method, deadline, and any extension.

Identify which filing applies

These forms serve different purposes and are not interchangeable. A plan may have more than one filing obligation, depending on its type and what happened during the plan year.

Form What it covers Where it is filed Usual timing
5500 or 5500-SF Annual information for an ERISA-covered employee benefit plan; eligibility and schedules depend on the plan. Department of Labor’s EFAST2 system. Generally the last day of the seventh month after the plan year ends; typically July 31 for a calendar-year plan. IRS Form 5500 Corner.
5500-EZ Annual return for qualifying one-participant plans and certain foreign plans. EFAST2 when filed electronically; paper filing with the IRS is available in certain circumstances. Generally the last day of the seventh month after the plan year ends. IRS Form 5500 Corner.
8955-SSA Reports certain separated participants with deferred vested benefits. Filed separately with the IRS using a method allowed by the current instructions, such as FIRE or approved software; paper filing is also described. Generally the last day of the seventh month after the plan year ends, subject to extension rules. IRS Form 8955-SSA instructions.
5330 Reports excise taxes arising under specified employee-benefit-plan tax provisions. IRS Modernized e-file through an authorized provider; consult current instructions for any other permitted process. Varies by the tax provision and triggering event. IRS Form 5330 instructions.
5558 Requests an extension for specified employee-plan returns, including eligible Form 5500-series returns and Form 8955-SSA. EFAST2 electronically or paper filing with the IRS, as described by the IRS. Submit by the normal due date for the extension requested. IRS Form 5500 Corner.

Choose the right annual return and filing system

Form 5500 or Form 5500-SF

Covered plans generally submit Form 5500 or Form 5500-SF electronically through EFAST2. The IRS identifies the employer maintaining the plan or the plan administrator as the filer for covered plans. Which form and schedules are appropriate depends on the plan’s eligibility and circumstances, so check the instructions for the return year rather than choosing the short form by assumption. The IRS’s 401(k) plan sponsor filing guide also summarizes sponsor reporting responsibilities.

Form 5500-EZ

Form 5500-EZ is generally for a one-participant plan covering only an individual (and spouse) who wholly owns a business, or partners and their spouses in a partnership, and for certain foreign plans. EFAST2 can be used for electronic submissions. Paper filing may be available where permitted; verify the current form instructions and e-file rules before mailing a return.

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For relevant plan years beginning on or after January 1, 2024, IRS guidance generally applies a 10-return threshold to mandatory e-filing of Forms 5500-EZ and 8955-SSA. The rule concerns the number of returns the filer must submit; check the IRS guidance for how the threshold applies and whether a waiver or exception is available: IRS mandatory e-filing guidance.

File Form 8955-SSA separately

Form 8955-SSA is an IRS filing for plan administrators of plans subject to ERISA section 203 vesting standards when separated participants have deferred vested benefits and a filing is required. It is not an attachment to Form 5500 or Form 5500-SF. Follow the current Form 8955-SSA instructions for the permitted filing method, e-file threshold, and any hardship or administrative exception. IRS instructions describe FIRE e-filing, approved software, and paper options.

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Determine whether Form 5330 is required

Form 5330 reports excise taxes tied to specified employee-plan tax provisions. The IRS instructions cover situations including certain minimum-funding failures, prohibited transactions, and excess contributions, among other cases. It does not replace Form 5500: one filing reports annual plan information, while the other reports applicable excise taxes.

Form 5330 deadlines are not uniform. The applicable Internal Revenue Code provision determines the deadline, which may be measured from a plan year, an employer tax year, or a triggering event. The IRS permits electronic filing through Modernized e-file using an authorized provider. Check the current Form 5330 instructions for the tax provision and filing procedure that match the situation.

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Calendar due dates and extensions

For Form 5500-series returns and Form 8955-SSA, the usual due date is the last day of the seventh month after the plan year ends. For a calendar-year plan, that is generally July 31. If the due date falls on a weekend or legal holiday, follow the applicable instructions for the next-business-day rule.

Form 5558 for eligible returns

A timely Form 5558 generally requests a one-time extension of up to 2½ months for eligible Form 5500-series returns and Form 8955-SSA. The IRS says Form 5558 can be filed electronically through EFAST2 or on paper beginning January 1, 2025. Its instructions also describe circumstances in which an employer’s federal income-tax return extension can automatically extend Form 8955-SSA. Check the current instructions to confirm eligibility and filing details. See the IRS Form 5500 Corner and Form 8955-SSA instructions.

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Form 8868 for Form 5330

Do not apply the seventh-month deadline or Form 5558 extension rules automatically to Form 5330. Under current IRS guidance, use Form 8868 to request an extension for Form 5330, and confirm the applicable deadline in the Form 5330 instructions.

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A practical filing workflow

  1. Classify the plan. Determine the plan arrangement, whether it is subject to ERISA, and whether it qualifies as a one-participant or foreign plan.
  2. Select the annual return. Use the current year’s instructions to establish whether Form 5500, 5500-SF, or 5500-EZ applies and which schedules are required.
  3. Check for Form 8955-SSA. Separately assess whether separated participants have deferred vested benefits that trigger a filing. Do not attach this form to the EFAST2 Form 5500 submission.
  4. Check for excise-tax events. Determine whether an event or condition creates a Form 5330 obligation, then identify the deadline under the specific tax provision.
  5. Confirm the filing channel. Check the number of returns the filer must submit, the relevant plan year, and any e-filing waiver or exception before choosing EFAST2, an IRS filing method, or paper where allowed.
  6. Calendar and document the filing. Submit by the applicable due date or request an extension with the correct form when eligible. Retain filing and acceptance confirmations and supporting records.

Use the instructions for the return year

Federal filing guidance can change by form edition and plan year, including deadlines, e-file thresholds, exceptions, and procedures. The IRS sources here describe general federal requirements, not a determination of any particular plan’s obligations. Before filing, use the instructions for the applicable return year and confirm the form-specific rules with the IRS.

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