Late Form 5500 Filings

Form 5500 Late Filing Penalties

Late Form 5500 filings can create federal penalty exposure. The Department of Labor also maintains the Delinquent Filer Voluntary Compliance Program (DFVCP) for eligible filers who satisfy the program requirements.

Updated September 6, 2026 • Verify current agency instructions before filing.

Late Form 5500 filings can create federal penalty exposure. The Department of Labor also maintains the Delinquent Filer Voluntary Compliance Program (DFVCP) for eligible filers who satisfy the program requirements.

Start by separating two questions

  1. What penalties could apply to the late filing? Statutory and agency penalties are not the same as the reduced DFVCP amount.
  2. Is the plan eligible for DFVCP? Eligibility and filing steps matter; paying a reduced amount by itself does not complete the program.

DFVCP reduced amounts

The DOL DFVCP calculator generally uses $10 per day and applies per-filing and per-plan caps. Small and large plans have different caps, and special caps can apply to certain 501(c)(3), Top Hat and apprenticeship filings.

Use the Free DFVCP Calculator

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Frequently Asked Questions

Is Form 5500 filed with the IRS on paper?

Form 5500 and Form 5500-SF are generally filed electronically through the Department of Labor EFAST2 system.

Does a Form 5558 extension extend every deadline?

No. Form 5558 provides an extension for specified returns when properly filed; it does not change every related compliance or payment deadline.

Where should I verify the current filing rules?

Use the current DOL Form 5500 Series page, EFAST2 resources, and the IRS Form 5500 Corner.