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Form 5500 Rescue Clock: the due date, the deadline you can still make, and what a late filing costs

Form 5500 is the annual return that ERISA plans file with the Department of Labor and the IRS, due on the last day of the seventh month after the plan year ends. Enter a plan year end, or paste a list of plans, and get the statutory date, the Form 5558 extended date, whether DFVCP is still open, and what each agency can charge. One plan or three hundred pasted at once. Free, no sign up, nothing stored.

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.

One plan

Anything that tells you which plan this is. It is printed on the card and in the register.
The last day of the plan year the report covers. A short plan year works the same way: only the month counts.
Form 5500-EZ is an owner-only plan and sits outside DFVCP. The tool still gives its due date and points to the IRS program instead.
Count participants at the beginning of the plan year: line 5 for welfare and defined benefit plans, line 6g(1) (participants with account balances) for a defined contribution plan, line 6g(2) for a defined contribution plan's first return. Fewer than 100 is a small plan.
Leave it blank if the report is not filed yet. The tool then measures to the as-of date below.
Form 5558 only counts if it was filed on or before the normal due date. The automatic extension only works when the plan year and the employer's tax year are the same.
A small plan of a 501(c)(3) sponsor has one lower cap for the whole DFVCP submission.
A Notice of Intent to Assess a Penalty, or any DOL letter about a missing report for this plan year. It closes DFVCP for the year.
Other delinquent years of this same plan that you will send in the same submission. Each is assumed to sit at its own per-report cap. Zero if this is the only late year.
Owner-only plans that filed a 5500-SF instead of a 5500-EZ. These sit outside DFVCP.
Defaults to today. Change it to see the figures on another date.

Results

This is a calculation, not legal advice. Confirm with your plan counsel.

What this tool does not do

Who made this

An AI Transformation firm out of Google and Microsoft. We build AI into the workflows your team already runs.

This clock is one plan book question answered for free. The same engineers build the rest of the TPA calendar: the missing filings, the notices, the audits, the reminders, read from your own records instead of typed in.

Speak with our team

When is Form 5500 due?

Form 5500 is the annual return that employee benefit plans covered by ERISA file with the Department of Labor and the IRS through EFAST2, and it is due on the last day of the seventh month after the plan year ends. For a calendar-year plan that is the end of July. For a plan year ending in June it is the end of January. The clock returns the exact date for any month end and for a short plan year. Department of Labor, Form 5500

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 shows both dates, and late days still count from the due date itself. The due dates page has the rule and the one place the IRS and the Department of Labor differ.

Under 29 CFR 2520.104a-5(a)(2), the Form 5500 annual return is due on the last day of the seventh month following the close of the plan year.

The same date applies to Form 5500-SF for small plans and Form 5500-EZ for one-participant plans. What differs is not the deadline but what happens after it is missed, which is the reason this clock exists.

What is the Form 5500 deadline after a Form 5558 extension?

Form 5558 is the extension request. Filed on or before the statutory date, it pushes the due date out by two and a half months. The clock returns both dates side by side, because a plan book usually has some plans on each. IRS, About Form 5558

Under the 2025 Instructions for Form 5500, Extension of Time To File Using Form 5558, page 4, a plan administrator who files Form 5558 on or before the normal due date receives an extension of two and a half months to file the Form 5500.

A Form 5558 filed after the statutory date does not work. The plan is late from the original date. The extension page also covers the automatic corporate-return route, which some plans can use without filing a 5558 at all.

Does an extension reduce the DFVCP fee?

No, and this is the one thing on this site worth reading if you read nothing else. One late filing is counted twice, on two clocks that start on different days.

Under 78 FR 6135, Section 3.03(b)(1), the DFVCP fee is $10 for each day the annual report is filed late, and the fee runs from the original due date, without regard to any extension.

The IRS count is the opposite. A plan that filed a valid Form 5558 and then missed the extended date has an IRS count beginning after the extended date and a DFVCP fee counted from the original date, as though no extension existed. Most guidance treats the extended date as the start for both. The clock keeps them apart. EBSA, DFVCP

What does the clock do with a late 5500 filing?

It answers the question the DOL calculator does not. That calculator prices a DFVCP filing once it is in EFAST2, and does it well. It does not say whether DFVCP is still open for the plan, what the exposure is on each side if you do nothing, or what the IRS relief route is once you pay. This clock does those three things, for one plan or a pasted list. DFVCP penalty calculator

For a late 5500 filing it returns: the statutory date; the extended date if a Form 5558 went in; both day counts; whether the Department of Labor's Delinquent Filer Voluntary Compliance Program is open or closed for that plan; the DFVCP fee at the right cap for the plan's size; both agencies' exposure side by side, never summed; and the IRS relief route that follows a DFVCP filing. It runs in the browser. Nothing entered leaves the page, and nothing is filed with either agency. EFAST2

Is DFVCP still open for this plan?

DFVCP is the Department of Labor's program for late filers. Pay a fee, file the late return through EFAST2, and the Department does not assess its own penalty. One door, one condition: the Department must not yet have given written notice of the failure to file. A letter ends eligibility for that plan year, on arrival. That is the decision the clock states first, in one word, open or closed. EBSA, DFVCP

The fee is capped, and the caps come in pairs. A small plan pays at most $750 per annual report or $1,500 per plan where one submission covers several late years, whichever is greater; for a large plan the pair is $2,000 and $4,000, under 78 FR 6135, Section 3.03(b). Which pair applies is the participant count at the start of the plan year, on the small plan or large plan page. Form 5500-EZ filers are outside DFVCP because a one-participant plan is not a Title I plan, so the clock routes them to the IRS program instead.

What does the Department of Labor charge, against what the IRS charges?

Two agencies, two statutes, two figures. The clock shows them in two columns and never adds them. One is a discretionary maximum, the other a fixed daily rate with a cap, and a sum of the two is a liability nobody assesses.

Under ERISA section 502(c)(2), the Department of Labor may assess up to $2,739 a day for 2026 against an administrator who fails to file, the figure carried into 2026 by the Department's notification at 91 FR 31358, published 27 May 2026 and indexed under 29 CFR 2575.3 and the Department of Labor's annual adjustment table at 90 FR 1854.

Under 26 U.S.C. 6652(e), the IRS penalty for a late annual return is $250 a day, capped at $150,000 per return, and 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.

The Department's figure did not rise this year: it is the same as 2025, for a reason the Department published, and what changed has the citation. The DFVCP fee switches off the Department's column. The IRS column comes off on a condition: under IRS Notice 2014-35, IRS relief for a DFVCP filer depends on any Form 8955-SSA required for the same year being filed separately with the IRS, on paper. That form does not go through EFAST2, so it is the step most delinquent filers miss. The clock takes no input for it, so it writes the relief route and leaves that condition to you and the census. IRS, About Form 8955-SSA

Who is the Form 5500 Rescue Clock for?

Third-party administrators first. A TPA holds hundreds of plans with plan year ends across the calendar, and every January the same run happens by hand: which plans missed the seventh month, which 5558s went in, which clients have had a letter. Book mode takes that list, a header line and then one plan per line, and returns one register row per plan sorted by what is closing soonest.

Benefits brokers second, because a late Form 5500 in a client's welfare plan surfaces at renewal, and walking in with the register already built is a different meeting from finding out together. CPA firms third, for the same reason at audit time. Single employers last: if you hold one plan, the clock is free, the answer is on the screen in under a minute, and you are done. The TPA and broker page covers the list format and the recurring version. IRS Form 5500 corner

The clock is built and kept by 02Launch, an AI engineering firm out of Google and Microsoft. The rules behind it are cited paragraph by paragraph, the figures come from one register verified against the primary sources, and where the clock and an agency disagree, the agency is right and the clock gets fixed.

Questions

When is Form 5500 due?

On the last day of the seventh month after the plan year ends. For a calendar-year plan that is the end of July. Form 5558, filed by that date, extends it by two and a half months. The clock returns the exact statutory and extended dates for any plan year end. If that date falls on a weekend or federal holiday, the next working day is still on time, and the clock shows both.

What is Form 5500?

The annual return/report that employee benefit plans covered by ERISA file with the Department of Labor and the IRS through EFAST2. Small plans file Form 5500-SF and one-participant plans file Form 5500-EZ. It is not the US Navy supply form of the same number.

Does a Form 5558 extension reduce the DFVCP fee?

No. Under 78 FR 6135, Section 3.03(b)(1), the fee runs from the original due date, without regard to any extension. The IRS count works the other way: 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. One late filing, two day counts, and the clock shows both.

What is DFVCP?

The Department of Labor's Delinquent Filer Voluntary Compliance Program. A late filer pays $10 a day, capped in pairs at $750 per report or $1,500 per plan for a small plan and $2,000 or $4,000 for a large one, files through EFAST2, and the Department does not assess its own penalty. It closes for a plan once the Department has given written notice of the failure to file.

What is the penalty for a late Form 5500?

Two penalties from two agencies, never summed. The Department of Labor may assess up to $2,739 a day for 2026 under ERISA section 502(c)(2), the same figure as 2025. The IRS penalty under Internal Revenue Code section 6652(e) is $250 a day, capped at $150,000 per return.

Can I run a whole list of plans through the clock?

Yes. Start with a header line naming the columns you have, such as plan, pye, type, count, filed, ext and notice, then one line per plan. The columns can go in any order and only the header has to match. Include the plan name, because a plan's late years are grouped on it and the per-plan cap only applies inside a group. The clock returns one register row per plan with both dates, both day counts, DFVCP open or closed and both agencies' exposure. The Form 8955-SSA condition is a census question the clock cannot test, so it reports the relief route and leaves that column to you. Nothing pasted leaves the page.

Who made this

An AI Transformation firm out of Google and Microsoft. We build AI into the workflows your team already runs.

This clock is one plan book question answered for free. The same engineers build the rest of the TPA calendar: the missing filings, the notices, the audits, the reminders, read from your own records instead of typed in.

Speak with our team

More on Form 5500