Form 5500 due date for calendar plans
Every employer-sponsored ERISA welfare or pension plan files Form 5500 annually. The deadline is keyed to the plan-year-end date, and most plans file under the standard Form 5558 extension. Here's the rule in one paragraph, with a calculator that tells you both dates for your plan.
The rule, in one paragraph
Form 5500 is due on the last day of the seventh calendar month after the end of the plan year. For a calendar-year plan (PYE December 31), that's July 31 of the following year. Filing Form 5558 by the original due date extends the deadline by another 2½ calendar months. For the calendar-year plan, the extended deadline becomes October 15.
The math holds for any plan-year-end. A June 30 PYE has an original due date of January 31 and an extended due date of April 15. A September 30 PYE has an original due date of April 30 and an extended due date of July 15. The calculator below runs the math for any date you enter and shows how many days are remaining (or how many you've passed).
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The original due date is the last day of the seventh calendar month after plan-year end. With a Form 5558 extension filed by the original due date, the deadline is 2½ calendar months after that.
Why the dates matter
Form 5500 is the public record of every employer benefit plan in the United States. Schedule A discloses insurance contracts and broker compensation. Schedule C discloses service-provider compensation and the non-disclosure indicator that ERISA fee-litigation plaintiffs filter on. Schedule H carries the audit opinion for large plans. None of those filings exist if the Form 5500 itself isn't filed on time.
Late filings expose the sponsor to $2,739 per day uncapped under ERISA §502(c)(2) and $250 per day capped at $150,000 per return under IRC §6652(e). The Delinquent Filer Voluntary Compliance Program caps the same exposure at $750–$4,000 per plan, but only before the DOL contacts the sponsor.
Filing the extension is automatic — but it must be filed in time
Form 5558 doesn't require a reason. It's an automatic extension. But it must be received by the IRS on or before the original Form 5500 due date. A Form 5558 filed one day late is no longer a valid extension, and the original due date controls.
For pension plans (not welfare plans), the Form 5558 extension is tied to the corporate income-tax extension Form 7004 in some cases — confirm with your TPA or counsel before relying on a single extension to cover both filings.
What to do if you missed it
If the extended due date has passed without a filing, the Delinquent Filer Voluntary Compliance Program is the standard self-correction path. The DFVCP cost is capped at $750 (small plan) or $2,000 (large plan) per single late report and at $1,500 or $4,000 per multi-year submission, regardless of how many years are delinquent. The catch: DFVCP is only available before the DOL has notified the sponsor of the missed filing. Once a DOL contact letter arrives, the program closes and the standard statutory regime applies.
The Late-Filing Penalty Check on BenefitsLedger walks every welfare Form 5500 your sponsor has on record across plan years 2021–2025 and flags any year where a filing is missing.
Walk your filing history for missed Form 5500s
The Late-Filing Penalty Check walks every welfare Form 5500 your sponsor filed, flags continuity gaps, and surfaces DOL, IRS, and DFVCP exposure side by side.
Open the penalty checkSources
- DOL EBSA — Form 5500 Annual Return/Report — Authoritative landing page for the Form 5500 series.
- DOL EFAST2 — Form 5500 search and instructions — Filing portal and current-year instructions.
- ERISA §502(c)(2) civil-penalty rule — Statutory basis for the $2,739/day penalty cited under DOL exposure.