Form 5500 season for the 2024 plan year is already open.

The contribution gets the attention. The return gets the penalty. For a calendar-year plan, the 2024 Form 5500 series is due on July 31, 2025. That is the last day of the seventh month after the plan year ended. If you want until October 15, 2025, you file Form 5558 by the original due date. Beginning this year, Form 5558 can be filed electronically. None of that is new law in the dramatic sense. It is the ordinary season, and it is the season in which small plans get into trouble by assuming the corporate tax extension covered a form it did not cover, or covered it for fewer days than the owner remembers.

This briefing is the calendar, the forms, and the division of labor. It is written in May so that July is a filing date and not a discovery. Sterling Pension Group prepares and coordinates this work as a third-party administrator in West Hartford. We are not an actuarial firm. Where the return includes a defined benefit schedule, an independent Enrolled Actuary signs the actuarial certification. The administrator signs the return. Those are different signatures, and both have to exist before anyone hits submit.

What is due, and on what day

The IRS Form 5500 corner states the rule plainly. The return is generally due on the last day of the seventh month after the plan year ends. For a plan year that ended December 31, 2024, that day is July 31, 2025. The same date applies to Form 5500-SF and, on the same seventh-month pattern, to Form 5500-EZ. A fiscal-year plan has a different anniversary. If your plan year is not the calendar year, do not borrow July 31 from a colleague's plan. Count seven months from your own year-end.

Form 5558 is the extension. Filed on or before the original due date, on a proper form, it extends the Form 5500 series to the fifteenth day of the third month after the original due date. For a calendar-year plan that is October 15, 2025. It is automatic in the sense that a complete and timely Form 5558 is not a request the IRS sits on and maybe grants. It is not automatic in the sense that the extension exists because you intended it. If Form 5558 is late, the original due date stood.

There is a second path, and it is narrower than the folklore. The Form 5558 instructions provide that filers are granted an extension until the extended due date of the employer's federal income tax return, without filing Form 5558, if two conditions are both true. The plan year and the employer's tax year are the same, and the employer has been granted an extension of time to file the income tax return to a date later than the normal Form 5500 due date. Read the second condition carefully. The automatic extension lasts only until the extended due date of the tax return. For many S corporations and partnerships, that date is September 15, not October 15. A firm that extended its return to September 15 and filed nothing else has not bought October 15 for the Form 5500. To reach October 15, file Form 5558 by July 31, 2025. Owners who "know the accountant extended everything" should ask which form, and to which day.

Beginning January 1, 2025, Form 5558 can be filed electronically through EFAST2, or on paper with the IRS in Ogden. That electronic option is new for this filing season. It does not change the due date. It changes the way a timely extension gets into the system. The IRS notes the electronic option on the Form 5500 corner. The Department of Labor's page on Form 5500 reporting is the companion explanation of what the return is for. Use both. Do not rely on a summary in a newsletter that still describes Form 5558 as paper-only.

Form 5558 no longer extends Form 5330. That change is already in effect. Excise tax returns, including the return for a minimum-funding failure, use a different extension form. Do not attach a funding problem to the Form 5500 extension and assume you have extended the penalty return with it.

Which form, and where it goes

Form 5500 is the full annual return. Form 5500-SF is the short form for certain small plans that meet its conditions. Form 5500-EZ is the return for a one-participant plan, which generally means a plan that covers only the owner, or the owner and spouse, or partners and their spouses, and no other employees who are participants. A plan that covered a common-law employee during the year is not a one-participant plan because the owner thinks of the staff as temporary. Eligibility and the document decide.

Form 5500 and Form 5500-SF are filed electronically through EFAST2. They are not mailed. A Form 5500-EZ may be filed on paper or electronically. Electronic filing is usually the cleaner record, and it is the path we prefer when we prepare the return, but the paper option is a reason some owner-only plans have a different habit. The deadline does not change with the habit. A return that is complete in a folder on July 31 and submitted on August 2 is late.

The return asks about the plan's qualification, its financial condition, and its operations. For a defined benefit or cash balance plan it includes Schedule SB, the actuarial information, signed by an Enrolled Actuary. That schedule is not a worksheet the administrator prepares and the actuary initials if convenient. The certification is the actuary's. The rest of the return is the administrator's responsibility, even when a third-party administrator types it. Publication 560 describes the filing obligation at a small-business altitude. It will not complete Schedule SB.

Late filing is not a small administrative miss. IRS and Department of Labor penalties for a late Form 5500 are assessed per day and add up faster than owners expect, especially when more than one year is open. There is a delinquent filer program that can reduce the pain if you have never been notified. It is not as cheap as filing on time, and it is not available in every posture. The point of a May briefing is to stay out of it.

What has to be true before the return can be signed

The census for 2024 has to be finished. Compensation, dates, hours, ownership, and distributions or account activity have to match the payroll records and the trust statement. A defined benefit contribution that was deducted and a contribution that was actually deposited are not always the same number on the same day. The return reports the plan year. The deduction lives on the employer's return. Reconcile them before the actuary locks Schedule SB, not after the CPA asks why the two files disagree.

The trust statement for the year ended December 31, 2024, has to be final, not a custodian's interim print. Alternative investments, insurance contracts, and late-posted contributions are the usual reasons a statement is still "almost final" in May. Almost final is not a filing. If a contribution for 2024 was deposited in 2025 and treated as a receivable, the statement and the actuarial valuation have to tell the same story about that receivable. This is ordinary work. It is also the work that slips when everyone assumes someone else has the statement.

Participant counts drive more than curiosity. They affect whether a small-plan audit by an independent qualified public accountant is required. The rules here have changed in recent years and they are easy to misremember. Do not assume that "under 100" still means what it meant when the plan was adopted. Ask, with the count in hand, whether an accountant's report is part of this filing. Discovering the audit requirement in July is how extensions get used up on a problem that needed a firm, not a form.

Notices and the summary annual report, for plans that must provide one, sit on a related calendar. They are not the Form 5500, and finishing the return does not mean the participant communication is done. The administration page is the map of that work across the year. The deadline calendar is the list of dates without the narrative. Use the calendar to see July 31 and October 15 next to the funding dates, which are not the same dates. Minimum funding for a calendar-year defined benefit plan is generally September 15. An owner who wires the contribution and does not file the return has done half of two different jobs.

How the signatures are divided

The plan administrator signs the Form 5500 under penalty of perjury. In a small professional practice the administrator is often the owner, or the corporation itself acting through the owner. A third-party administrator can prepare the file, assemble the schedules, and transmit it. The TPA's preparation is not a substitute for the administrator's signature. Read the questions. A question about late deposits, prohibited transactions, or coverage failures is not a question to answer from memory in the signature box.

The Enrolled Actuary signs Schedule SB. Sterling Pension Group does not. We are not an actuarial firm. We coordinate the independent actuary's valuation with the census and with the filing. If the actuary does not have a final census and a final asset statement, the schedule is not ready, and the return is not ready, no matter how complete the rest of the form looks. The plan lifecycle after adoption is mostly this: each year the same facts have to be made true again, in time for someone to sign them.

Fees for the filing, the valuation, and the investment custody are different invoices. None of them is waived because the year felt simple. The fees briefing separates those categories so a single "plan fee" argument does not delay the signature. A dispute about an invoice in the last week of July is a common way to miss a due date that was known in January.

This briefing is not tax, legal, or actuarial advice. Penalties, delinquent-filer relief, and whether a particular transaction must be reported are questions for the professionals who sign the relevant forms. The dates above are the general calendar for a calendar-year plan. Your plan document and your plan year control if they differ.

What to do in the next two weeks

Confirm the plan year-end in the document. If it is December 31, write July 31, 2025 on the calendar as the Form 5500 due date, and decide now whether you are targeting that day or October 15, 2025. If you are targeting October, make sure Form 5558 will be filed by July 31, electronically or on paper. Do not rely on a tax extension that only runs to September 15.

Ask, in one email, for three things: the final trust statement for 2024, the final census, and confirmation of who is signing Schedule SB. If any of the three is not identified, the return is not in process. It is in a queue.

Read the administrator questions before the day you are asked to sign. If you have employees, confirm whether an accountant's audit report is required for this filing. If you are owner-only, confirm that 2024 stayed owner-only, including the treatment of anyone who was hired and let go.

Then send us the status of those three items. If we already administer the plan, we should be able to tell you which of them is in hand. If we do not, the next two weeks are still enough time to start a filing that is due at the end of July, and not enough time to start one at the end of July.