Form 14704 – 5500‑EZ Late Filer Penalty Relief Guide

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A solo 401(k) sponsor who skipped the Form 5500-EZ for a few years is looking at penalties that can dwarf the plan. Form 14704 is the routing slip that points a paper packet of those delinquent returns into the IRS penalty relief lane under Rev. Proc. 2015-32. It is a one-page transmittal that tops the submission, nothing more, but it has to be done right.

The fee is a flat three-tier schedule per plan submission: $500 for one delinquent return, $1,000 for two, and capped at $1,500 for three or more, with no per-return multiplier, paid by check to the United States Treasury and mailed to Ogden. The program covers non-ERISA one-participant plans and certain foreign plans, and you cannot e-file, EFAST2 does not qualify. One trap: if you already got a CP 283 late-filing notice for a year, that year is out and you look at reasonable cause instead.

Key Takeaways

• Form 14704 is the one‑page transmittal that tops your paper submission of delinquent Form 5500‑EZ returns to request fixed‑fee penalty relief under Rev. Proc. 2015‑32.
• The fee is a three‑tier flat schedule per plan submission – $500 for one delinquent return, $1,000 for two, and $1,500 for three or more (capped at $1,500, no per‑return multiplier) – and it must be paid by check to the United States Treasury.
• The program applies to non‑ERISA one‑participant plans and certain foreign plans. Do not e‑file. Electronic submissions, including EFAST2, do not qualify. Mail a paper packet.
• If you already received an IRS CP 283 late‑filing penalty notice for a year, that year is not eligible for this relief. Consider reasonable cause or appeals instead.
• Mail to the IRS Ogden address listed on the current IRS penalty relief page and the latest 5500‑EZ instructions. Use a trackable method and keep copies.

What Is Form 14704 and Who Needs It

Form 14704 is a transmittal schedule, a simple cover sheet that ties your late paper 5500‑EZ filings to the IRS Late Filer Penalty Relief Program in Rev. Proc. 2015‑32. It identifies your plan sponsor name, EIN, plan name and number, and it lists every delinquent plan year you are sending. It also documents the total fee so the IRS can match and post payment. You include one Form 14704 per plan, even if your packet contains several years.

You need this form if you are filing for a one‑participant plan or a qualifying foreign plan that missed one or more 5500‑EZ deadlines and you want the fixed‑fee relief instead of racking up daily penalties. This is only for paper submissions. If you try to send late 5500‑EZs through EFAST2, they will not count for this program.

Plain English: think of Form 14704 as your table of contents and receipt in one. It tells the IRS exactly what is in the packet and why you qualify for the fixed fee.

How Form 14704 And 5500‑EZ Work Together

Here is the flow that consistently works:

• Prepare a complete paper Form 5500‑EZ for each delinquent plan year, with all required schedules and attachments.
• For years that include Box D in Part I, check it. If the form year does not have Box D, write in red at the top margin of the first page, “Delinquent Return Filed under Rev. Proc. 2015‑32, Eligible for Penalty Relief.” Apply that marking on each late return.
• Complete Form 14704, list every delinquent year for the plan, total the fixed fee, and attach your check payable to United States Treasury. Attach Form 14704 to the top of the oldest return in the stack.
• Mail the packet to the Ogden address on the current IRS page. Use certified mail or an approved private delivery service and keep proof. Do not e‑file for this program.

We will zoom in on eligibility, fees, assembly details, and the most common mistakes next, so you can file with confidence and avoid preventable delays.

Eligibility, Ineligibility, And Edge Cases

You will save time by confirming eligibility first. The penalty relief program is limited and it is easy to disqualify a year without realizing it.

Who Is Typically Eligible

• One‑participant plans and certain foreign plans filing paper delinquent 5500‑EZ returns. These are non‑ERISA filers, which means Title I does not apply.
• A single submission can include multiple late years, as long as they are for the same plan, and you include one Form 14704 at the front.
• You must use paper returns for the delinquent years.

Covered Return Forms

• The program applies to Form 5500‑EZ delinquent filings, which must be mailed on paper. For years that do not include Box D, you add the red ink statement the IRS specifies.
• If your non‑ERISA plan used the older Form 5500 in certain earlier years, the IRS explains how to handle those late years with the current 5500‑EZ. Check the latest instructions before you prepare older years.

Ineligible Situations You Must Catch Early

• You received a CP 283 late‑filing penalty notice for that plan year. Once assessed, that year cannot use this program. Your options shift to paying, requesting reasonable cause, or appealing.
• You e‑filed the delinquent year through EFAST2. Electronic submissions do not qualify for this relief.
• Plans subject to Title I should look at the DOL DFVC program instead. That is a different agency and a different path.

Quick gut check: if you have a CP 283 in hand, stop and switch to reasonable cause or appeals. Do not mail a Form 14704 packet for that year, it will not qualify.

Fees, Caps, And How To Pay

The fee is simple and fixed, which is a relief when you are trying to budget.

• Three flat tiers per plan submission: $500 for one delinquent return, $1,000 for two, and $1,500 for three or more (capped at $1,500 – there is no per‑return multiplier). If you have three or more late years for the same plan in one packet, you will hit the cap.
• Pay by check or money order to the United States Treasury (EFTPS, Direct Pay, and credit or debit card payments are not accepted for this program). Write the plan sponsor EIN and plan number on the check, then attach the check to Form 14704.

Fast Reference Table

Item	Amount or Rule	Source
Fee tier (flat per plan submission)	$500 (1 return) / $1,000 (2) / $1,500 (3 or more, cap)	IRS Penalty Relief Program page, IRS FAQ
Per‑plan cap per submission	1,500	IRS Penalty Relief Program page, IRS FAQ
Payment method	Check to United States Treasury, attach to Form 14704	IRS FAQ
E‑filing allowed	No, paper only	IRS page and FAQ
Address	IRS Ogden, Utah, as listed on the current IRS page	IRS page

Sources for the table.

What To Gather Before You File

Use this short checklist so your packet is complete the first time.

• A separate, complete paper Form 5500‑EZ for each delinquent plan year, including all schedules and attachments the form year requires.
• The correct penalty relief marking on each return, either Box D checked or the red ink statement for older years.
• One completed Form 14704 that lists the plan and every delinquent year in the packet, attached to the oldest return.
• Your check for the fixed fee, with EIN and plan number written on it, attached to Form 14704.
• A trackable mailing method and a full copy set of everything you send. The IRS encourages mailing for this program and provides the Ogden address.

Pro move: print a one‑page cover inventory for your own files that lists each year, the version of the form used, and the date you signed it. It makes follow up much easier if you ever need to call IRS Employee Plans.

Up next, I will show you how to complete Form 14704 line by line, how to mark each 5500‑EZ correctly, where to mail, and how to avoid the mistakes that trigger denials.

Complete Form 14704 Step by Step

You only get one page to get this right, so slow down and be precise. Here is the clean, repeatable process I use with sponsors and CPA firms when we prep a package.

Purpose Of Form 14704

Form 14704 is the cover that tells the IRS what is inside your packet and why you qualify for the fixed fee relief under Rev. Proc. 2015‑32. It links your plan sponsor details, your plan information, and the list of late years to a single payment. Think of it as the table of contents, the routing slip, and the receipt.

• It consolidates all late years for one plan under a single submission.
• It associates your payment with the exact count of late returns.
• It reduces follow up because the IRS can match your EIN, plan number, and years at a glance.

If your packet is a book, Form 14704 is the title page that keeps every chapter in order.

Required Information Fields

Complete every field exactly as it appears on your 5500‑EZ returns. Small mismatches cause avoidable delays.

• Filer identification, legal name, mailing address, daytime phone, and EIN (Line 4 expressly forbids a Social Security Number, even when the plan sponsor is a sole proprietor – apply for an EIN on Form SS-4 first if you do not have one).
• Plan details, plan name, plan number, and each plan year you are transmitting (Line 8 requires MM/DD/YY format with a two-digit year for each plan-year-end date, not MM/DD/YYYY).
• Packet summary, total count of delinquent returns enclosed for this plan.
• Fee disclosure: a single flat tier per plan submission – $500 for one delinquent return, $1,000 for two, or $1,500 for three or more (capped at $1,500, no per‑return multiplier).
• Signature and date by an authorized representative.

Field Group	What to Enter	Practical Tip
Filer ID	Legal name, EIN, address, phone	Match the EIN and name to each 5500‑EZ exactly
Plan Details	Plan name, plan number, each late year	Put the oldest delinquent return under Form 14704
Fees and Cert	Total fee, payment method, signature	$500 (1) / $1,000 (2) / $1,500 (3 or more), capped at $1,500 per plan

Submission And Fees

• Attach one, and only one, Form 14704 to the top of the oldest delinquent 5500‑EZ for the plan.
• Pick the matching flat tier for the count of delinquent returns in the packet – $500 for one, $1,000 for two, or $1,500 for three or more (capped at $1,500, no per‑return multiplier) – and pay by check to United States Treasury. Write the EIN and plan number on the check.
• Stack the remaining late returns under the oldest year in chronological order.
• Paper only for this program. Do not e‑file these late returns.

A Quick Scenario Example

You discover your solo 401(k) missed three years, 2021, 2022, and 2023.

• You prepare three complete paper 5500‑EZs, each signed for its year.
• You mark each return for penalty relief. For years with Box D, check it. For a year without Box D, add the red statement at the top margin.
• You complete one Form 14704 listing 2021, 2022, and 2023.
• Your total fee is $1,500 because the plan hits the cap.
• You attach the check to Form 14704, put Form 14704 on top of the 2021 return, then 2022, then 2023, and you mail the packet by a trackable method.

Mini‑Checklist You Can Print

• One Form 14704 for the plan, signed and dated
• Oldest late 5500‑EZ directly under Form 14704
• All late 5500‑EZs complete, signed, and properly marked for penalty relief
• Check to United States Treasury with EIN and plan number noted
• Copy set of everything and a trackable mailing label saved

Prepare Each Delinquent 5500‑EZ Correctly

Accuracy on each late return matters as much as the cover sheet. Treat every year like a fresh filing.

• Use the correct‑year Form 5500‑EZ for 1990 forward. For pre‑1990, the IRS allows the current 5500‑EZ with the correct plan year begin and end dates.
• Include every required schedule and attachment that the specific form year requires.
• Sign and date each return. If it is a final year, check the final‑year items in Part I.
• Keep plan name, plan number, and EIN consistent across all years.

Required 5500‑EZ Markings For Penalty Relief

The program depends on clear markings on the face of each return.

• If the form year includes Part I, Box D, check it to indicate Penalty Relief.
• If there is no Box D on that form version, write in red at the top margin, “Delinquent Return Submitted under Rev. Proc. 2015‑32, Eligible for Penalty Relief.”
• Apply the same marking rules consistently on every late return in your packet.

If the IRS cannot see Box D or the red statement, the return may not be routed into the relief program. Do not skip this step.

Where To Mail And How To Pay

• Mail your paper packet to the IRS Ogden Submission Processing Center address shown in the current IRS instructions for the penalty relief program.
• Use certified mail or an approved private delivery service so you have a tracking number.
• Include a single check for the fee total for that plan’s packet. Make it payable to United States Treasury, write the EIN and plan number on the memo line, and place the check in front with Form 14704.

Processing Time And Proof Of Filing

Processing is not instant, and that is normal.

• Many filers see the fee clear first, then relief post later.
• Keep a full copy of your packet, your tracking receipt, and the date delivered.
• If you need to follow up, have your tracking number, plan sponsor EIN, and the Form 14704 details handy when you call IRS Employee Plans.

Quick Assembly Order

• Form 14704, signed, with check attached
• Oldest delinquent 5500‑EZ, signed and marked, with schedules
• Next late 5500‑EZs, each complete, in chronological order
• Copy set and a short internal inventory sheet for your records

Tip for firms, keep a standardized binder or digital folder structure, one folder per plan, with subfolders for each plan year and a top‑level folder for the transmittal and payment copy. It reduces review time and rework.

Common Mistakes That Trigger Denials Or Delays

These checklists are copy-paste ready for your firm's SOP binder. Each item is a single executable step a preparer can tick off without interpretation.

For CPA and EA Firms Handling Multiple Plans

If your team is assembling several late packets at once, standardize the process so reviewers do not get trapped in rework.

• Use a uniform SOP with a one‑page intake sheet that captures EIN, plan number, plan name, late years, and CP 283 status.
• Standardize file names for each year and include the Box D or red statement proof in the year’s folder.
• Run an internal checklist that requires fee recalculation and a second person sign‑off before mailing.
• Keep a simple tracker with columns for mailed date, carrier, tracking number, fee amount, and delivered date.

A quick note, if your firm is short on capacity during peak season, a trained offshore staffing partner can help with structured workpapers, SOP‑driven prep, and trackable mailings while you keep review control. At Accountably, we do this with U.S.‑led onboarding, clear SOPs, and layered review so your partners stay out of avoidable loops and your clients get clean filings. Use support only where it adds control, not noise.

Conclusion And Next Steps

You now have a complete, step by step path to use Form 14704 the way the IRS expects. Confirm eligibility, build complete paper 5500‑EZs for every late year, mark each return correctly, calculate the fee using the matching flat tier for the packet ($500 for one return, $1,000 for two, or $1,500 for three or more – capped at $1,500, no per‑return multiplier), and mail the packet by a trackable method. Keep copies, keep proof, and follow up only when needed. If a CP 283 has already been issued for a year, switch to reasonable cause or appeals rather than wasting time on an ineligible packet.

Reusable Checklists

Form 14704 hits a firm as cleanup work, not a recurring cycle. A client mentions a self-directed solo 401(k) at intake, my team runs the 5500-EZ filing history, and three or four delinquent plan years surface at once. The window to act is narrow because Rev. Proc. 2015-32 (per IRS.gov, effective for submissions filed on or after June 3, 2015) closes eligibility the moment a CP 283 notice lands on the mat for any year in the package, and the IRS Form 5500 Corner makes clear the relief route is paper to Ogden, not EFAST2.

The fix is to treat every Form 14704 engagement as a fixed-scope packet with a hard mailing date, not as ad-hoc plan work absorbed into busy-season volume.

• Open every engagement with a CP 283 status check per delinquent plan year before promising relief; if a notice is out for a year, that year is off the program and routes to reasonable-cause abatement instead.
• Pull the year-specific Form 5500-EZ for each delinquent plan year from IRS Prior Year Forms, not the current-year version, and stack the returns oldest-first under one Form 14704.
• Reconcile Line 4 to the plan sponsor's EIN (never an SSN, even for sole-proprietor sponsors), Line 7 plan name to the plan document, and Line 8 plan-year-end dates to the MM/DD/YY format the form requires.
• Match the Line 9 payment tier to the count of delinquent returns in the packet: $500 for one, $1,000 for two, $1,500 for three or more, then issue a single check payable to United States Treasury for that exact amount.
• Keep separate plans in separate packets with separate transmittals and separate checks; never combine plans under one Form 14704 to stay under the $1,500 cap.

Accountably runs Form 14704 cleanup packets as a defined production lane inside our U.S. tax outsourcing service, so the prior-year form pulls, line-level review, Ogden mailing log, and CP 283 eligibility check stay disciplined while reviewers focus on the engagements that pay.

Keep 14704 Season From Stalling

Form 14704 work concentrates risk into a single mailed envelope. The Form 14704 transmittal (May 2015 revision per IRS.gov) must be attached to the oldest delinquent Form 5500-EZ in the submission, the entire packet ships on paper to the IRS service center at Ogden, UT, and the IRS Form 5500 Corner confirms there is no EFAST2 path for plans cured through the Rev. Proc. 2015-32 program. One missed year, one mistyped EIN on Line 4, or one CP 283 surprise can knock the whole packet off-program before it reaches the mailroom.

The way to keep cleanup season from stalling is to lock the workflow at the form-line level: every field on Form 14704 has a known source document, every delinquent plan year has a documented eligibility check, and the payment math is decided before the package is assembled.

• Run a CP 283 status check for each delinquent plan year at intake; under Rev. Proc. 2015-32 (effective for submissions filed on or after June 3, 2015), any year with a notice already issued is off the program and has to route to reasonable-cause abatement instead.
• Pull the year-specific Form 5500-EZ for each delinquent plan year from IRS Prior Year Forms; the current-year form is the wrong document for prior plan years and breaks the program requirement.
• Tie Line 1 (applicant name), Line 4 (the plan sponsor's EIN, never an SSN even for a sole-proprietor sponsor), Line 6 (three-digit plan number), and Line 7 (plan name) back to the plan document and the sponsor's SS-4 file, not to memory.
• Enter every Line 8 plan-year-end date in MM/DD/YY format, oldest year first, and check exactly one Line 9 tier on a single transmittal: $500 for one delinquent return, $1,000 for two, or $1,500 for three or more, with no per-year multiplication.
• Mail one packet per plan with one check or money order for the matching tier payable to United States Treasury; combining two plans under one Form 14704 to stay at the $1,500 cap breaks the one-submission-per-plan rule in the program instructions.

Accountably handles 14704 cleanup as a standardized production lane inside our U.S. tax outsourcing service, so the CP 283 check, prior-year form pulls, line-by-line review, and Ogden mailing log stay disciplined and the packet reaches the service center complete on the first send.

FAQs

What happens if you do not file Form 5500‑EZ?

Penalties can stack up quickly per return, and the IRS can issue a CP 283 late‑filing notice. Non‑filing also increases audit risk and creates headaches if you ever terminate or roll assets. Act fast, prepare the delinquent returns, and either use the fixed‑fee program through Form 14704 or document reasonable cause.

Is the IRS waiving penalties for 2020 or 2021?

No blanket waiver applies. You must either qualify for penalty relief under the fixed‑fee program by mailing a paper packet with Form 14704 or pursue reasonable cause abatement. A CP 283 for a given year removes that year from eligibility for the fixed‑fee program.

What is the DOL DFVC program, and does it apply here?

DFVC is the Department of Labor’s program for Title I plans that file the standard Form 5500. One‑participant plans using Form 5500‑EZ are not Title I filers, so they generally do not use DFVC. If your plan is Title I, follow DFVC. If it is a one‑participant or eligible foreign plan, use the IRS fixed‑fee program with Form 14704.

Do I e‑file the late 5500‑EZs to qualify?

No. E‑filed delinquent returns do not qualify for this program. You must mail paper returns, mark each one for penalty relief, and place a single Form 14704 on top of the oldest year.

How long does processing take?

Expect weeks, not days. Many filers see the fee clear first, then the relief posting follows. Keep copies and tracking proof, and call the IRS Employee Plans line with your tracking number and plan information if you need to check status.

Can I combine multiple plans in one packet and one check?

No. The fee cap applies per plan per submission, and you prepare a separate Form 14704 for each plan. Mail separate packets and write separate checks.

What if my old form year does not show Box D?

Add the required red statement at the top margin of the first page, “Delinquent Return Submitted under Rev. Proc. 2015‑32, Eligible for Penalty Relief.” Apply it consistently on each older‑format return.