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Owner-only plans grow without a payroll team watching them, and the $250,000 aggregate-asset trigger tends to sneak up after a strong market year or a single late rollover. By the time it matters, the July 31 deadline lands right in the middle of extension work for everything else.
Form 5500-EZ is the annual return for one-participant plans, Solo 401(k)s and owner-only defined benefit plans among them, filed under IRC §6058(a). You file when combined assets across all one-participant plans of the sponsor exceed $250,000 at plan year end, and always for the plan's final year. The aggregate-asset test is what people miss, since it runs across multiple plans rather than one. You can extend by up to 2.5 months with Form 5558 filed by the original due date, and late filers have a relief path through Form 14704.
Key Takeaways
- Form 5500-EZ is the annual return for one-participant and certain foreign plans, for example Solo 401(k) and owner-only defined benefit plans.
- You must file when combined one-participant plan assets exceed $250,000 at plan year end, and you must also file for the final plan year.
- The due date is the last day of the seventh month after plan year end, for calendar-year plans that is typically July 31. You can extend by up to 2.5 months with Form 5558 filed by the original due date.
- Form 5500-EZ may be filed either electronically through EFAST2 or on paper with the IRS, and many filers are now subject to the IRS electronic filing mandate if they file at least 10 federal returns in the year.
- Late filings can trigger steep penalties. Penalty relief may be available through Form 14704 or reasonable cause, so act quickly if you miss a deadline.
What is Form 5500-EZ
Form 5500-EZ is the annual return that owner-only and certain foreign retirement plans file to report plan-level data, for example assets at year end, contributions, rollovers, loans, and plan features. It satisfies the plan’s reporting duty and creates a clear compliance record.
Think of 5500-EZ as your plan’s yearly report card. It shows what the plan holds, what went in and out, and whether anything needs attention.
You file for a one-participant plan when the combined assets across all of your one-participant plans are above $250,000 at the end of the plan year, and you always file for the plan’s final year. The “combined” point trips people up, since the threshold is not per plan or per account, it is the total across all one-participant plans you maintain.
Who must file
If you sponsor a one-participant plan, you are the filer once you hit the threshold or terminate. “One-participant” includes plans that cover only you, or you and your spouse, if you both own the business, and owner-only partnerships. SEP-IRAs are not qualified plans and do not file 5500-EZ.
One-participant plans, at a glance
- Your plan covers only you, or you and your spouse, and you both own the entire business, or it covers one or more partners and their spouses.
- You file 5500-EZ when your combined one-participant plan assets exceed $250,000 at year end, and for the final plan year even if below the threshold.
- If you filed in a prior year, keep your reporting consistent, especially if you hover near the threshold. This helps maintain a clear compliance trail.
Quick filing posture table
| Situation | What you do |
| Solo 401(k) for you or you and spouse | Monitor year-end assets, file if over threshold |
| Combined one-participant plans under $250,000 | No filing required for that year, consider filing if you are close and want clean continuity |
| Prior-year filer, now under threshold | Consider continued filing for consistency, and be prepared to file again if markets move |
| Plan termination | File a final 5500-EZ for that plan year |
How 5500-EZ filing works today
- Electronic filing, EFAST2. One-participant plans may file 5500-EZ either electronically through EFAST2 or on paper with the IRS.
- Mandatory e-file threshold. If you file at least 10 federal returns in the calendar year that includes the first day of the plan year, you must e-file 5500-EZ for plan years beginning on or after January 1, 2024.
- Paper filing. Only if exempt from the e-file mandate or you have an undue hardship waiver, mail to the IRS Ogden, UT address on the IRS site.
Tip from the trenches, if you try to file a paper return even though you are required to e-file, the IRS can treat that as not filed. That is a fast path to penalties, so get your EFAST2 credentials in place early.
Where Accountably fits, briefly
When you are juggling close, plan loans, or late rollovers, prep time spikes. Our team can help standardize workpapers, tie out year-end values, and submit clean, signed EFAST2 filings, so you spend your time on strategy, not chasing documents. We keep this light, since most readers just want to know how to file, but if you need hands-on help, we can step in where it genuinely saves you time.
The $250,000 threshold, explained
The filing trigger is measured on the last day of your plan year and it looks at the combined assets of all one-participant plans you maintain. If the total is above $250,000, you file a 5500-EZ for each one-participant plan, even those with less than $250,000 individually. For the plan’s final year, you file regardless of balance.
What counts toward assets, think fair market value at year end plus anything the instructions treat as an asset, including participant loans and illiquid holdings like real estate or private notes. Total plan assets include rollovers and unrealized gains or losses that are already reflected in fair value.
Why “combined plans” trips people up
Owners often think the test is per plan or per person. The IRS guidance treats the threshold as a combined total across all your one-participant plans. Once the combined total exceeds the threshold, you file a 5500-EZ for each plan.
Practical example
You hold a Solo 401(k) and a small cash balance plan. On December 31, your Solo 401(k) shows $210,000 and the cash balance plan shows $55,000. Your combined owner-only plan assets are $265,000, so you file a 5500-EZ for both plans.
When filing is recommended, even if you are close
If you sit near the threshold, a late rollover, year-end contribution, or a market jump can push you over. Filing conservatively gives you a clean record and removes guessing games. As a bonus, filing starts the typical three-year clock that applies to these annual returns, which is one more reason to stay timely.
Near-threshold checklist
- Track December contributions, last-minute rollovers, and any loan offsets that hit in Q4.
- Get fair market values for illiquid assets early, and document your methods. Keep a copy of appraisals or valuation memos in your workpapers.
- If you previously filed and you hover just under $250,000, consider continued filing for continuity. It keeps your pattern clean for future years.
Determining fair market value, step by step
- Sum the fair market value of every one-participant plan you and, if applicable, your spouse maintain as of year end. Combine plans for the $250,000 test.
- Include plan assets the instructions list, for example participant loans, and include rollovers that settled by year end.
- Value illiquid positions with a reasonable, supportable estimate and keep the backup in your workpapers.
- If the combined year-end total is below $250,000, no filing is required for that year, except you must file a final return when the plan terminates.
A quick story from my desk
Late December, a founder rolled over $60,000 from an old 401(k) into a Solo 401(k). He thought he was still under the limit because the rollover landed after Christmas. We caught it while reconciling the year end. The combined balance ended above $250,000, so we filed 5500-EZs for both owner-only plans. It took an extra hour that week, and it saved a penalty letter six months later.
Deadlines and extensions
For most one-participant plans, your due date is the last day of the seventh month after the plan year ends, independent of your personal income tax return deadline. For calendar-year plans, circle July 31 (not April 15 or October 15, which apply to your 1040). If you need more time, file Form 5558 by the original due date and you will usually get up to a 2.5 month extension. Keep a copy of the extension and your proof of submission in the plan files.
Disaster or combat zone relief sometimes postpones deadlines. The DOL and PBGC generally follow IRS announcements, so if your area is affected, check current notices.
Final year returns
If you fully distribute or transfer all plan assets and terminate the plan, you must file a final 5500-EZ for that year and check the “final return” box. This applies even if the plan balance was under $250,000 before distribution.
Filing methods and tools
Most filers should use EFAST2. You can prepare and submit through the EFAST2 web tool, called IFILE, or EFAST2-approved software. Register to obtain electronic credentials, then sign and submit electronically. Keep the electronic acceptance and a signed copy in your plan records.
If you are exempt from the mandatory e-file rules, or you receive an undue hardship waiver, you may mail a paper 5500-EZ to the IRS Ogden, UT address shown on the IRS site. Otherwise, paper can be treated as not filed, which risks penalties.
| Method | Credentials | Tools |
| EFAST2 electronic | EFAST2 credentials | IFILE web tool |
| EFAST2 electronic | EFAST2 credentials | EFAST2-approved software |
| Paper, only if eligible | Not applicable | Mail to IRS Ogden, UT, per IRS site |
Common EFAST2 questions
- Can I still use 5500-SF instead of 5500-EZ, no, as long as you remain a one-participant plan. One-participant plans should file 5500-EZ, generally electronically. Note that one-participant status is tested on the first day of the plan year, so hiring a non-owner W-2 employee mid-year does not retroactively force you onto 5500-SF for that year, but the plan switches to Form 5500-SF (or Form 5500) starting the next plan year in which that employee is a participant on day 1.
- Who signs, the plan administrator or sponsor signs electronically using EFAST2 credentials. Keep the signed copy in your files.
- How do I extend, file Form 5558 by the original due date. You can file electronically where supported, or by mail if you prefer.
Quality control that saves you time
Here is a short prep list that keeps reviews quick and clean.
- Reconcile contributions, rollovers, and loan activity to your provider statements and payroll records.
- Tie the plan year-end balance to fair market value support, especially for private assets, loans, or real estate.
- Save the EFAST2 acceptance, the confirmation email, and your signed copy in a dated folder. Future you will thank you.
Where Accountably helps, when it actually helps
If your plan holds private assets, participant loans, or you manage more than one one-participant plan, the documentation can get messy. Our team builds standard workpapers, tags each value to a source, and runs the filing through EFAST2 with proper sign-offs. If that offloads the painful hours, we are here for it. If your filing is straightforward, the checklists here may be all you need.
Penalties and relief
Missing the deadline can get expensive fast. The IRS penalty often cited is $250 per day, capped at $150,000 per plan year. If you fall behind, act quickly and evaluate the IRS late-filer penalty relief program, which uses a fixed fee, commonly $500 per delinquent return up to a cap per submission. Reasonable cause relief is another route, but approval is not guaranteed.
Important detail, late-filer relief submissions typically require paper returns with Form 14704 on top, mailed to the IRS, and you must submit a separate Form 5500-EZ in the revision in effect for each delinquent plan year (do not combine multiple years on one return or use the current-year form for prior years). Electronically filed delinquent returns may not be eligible for that specific relief path, so follow the program instructions closely.
Why timeliness matters beyond penalties
Timely filing does more than avoid penalties. It also helps start the normal assessment clock that applies to these annual returns, which reduces the period of uncertainty. Late or missing filings can keep the clock open.
Practical tips and common pitfalls
- Confirm the $250,000 test on the last day of the plan year and combine all one-participant plans you maintain. Many sponsors mistakenly treat the threshold as per plan.
- Include participant loans in total plan assets for the asset line, and disclose outstanding participant loans in the loans section. Keep support for accrued interest.
- Use EFAST2 to e-file, or mail the paper return to the IRS Ogden, UT address if you prefer or cannot e-file. If you are subject to the electronic filing mandate and you send a paper return, the IRS can treat it as not filed.
- Need more time, submit Form 5558 by the original due date. Keep a copy in your records.
- Terminating the plan, file a final 5500-EZ and check the final return box, even if the balance was under the threshold before distribution.
Resources and disclaimers
Use official sources when you prepare or review your filing. Start with the IRS “About Form 5500-EZ” page and the current instructions. For e-filing mechanics, use the DOL’s EFAST2 FAQ and Quick Start materials. If you need an extension, see the IRS Form 5558 reminders. For late filings, read the IRS penalty relief page and Form 14704 instructions. Filers of Form 5500-EZ are not eligible for the DOL DFVCP program.
Note, this article focuses on United States rules. Always confirm whether special relief applies to your area if you are affected by a disaster or are serving in a combat zone.
Common Mistakes We See Every Season
The same handful of misses come up year after year, almost all of them tied to small assumptions about who files, when, and how. Catch these at intake and most 5500-EZ packages stay clean through review.
Reusable Checklists
These checklists are written to drop straight into a firm SOP. Copy the items into the engagement workpaper, walk the sponsor through them on a short call, and most of the common gaps close without rebuilding the wheel each cycle.
Year-end aggregate-asset test (run in January)
- List every one-participant plan the same sponsor maintains (Solo 401(k), profit-sharing, cash balance, owner-only defined benefit).
- Pull December 31 fair market value from each provider statement, including unrealized gains and losses already reflected in the statement.
- Add outstanding participant loans at face value to the asset line of the plan that holds them.
- Value illiquid positions (real estate, private notes, private equity) with a current appraisal or supportable valuation memo and store the backup in the workpaper.
- Sum the values across all one-participant plans of the sponsor. If the total exceeds $250,000, file Form 5500-EZ for each plan.
- Note in the file whether the sponsor crossed the threshold for the first time, since that flips the filing posture for future years even if assets later drop back below $250,000.
5500-EZ filing prep packet (run by June 15)
- Confirm EIN, 3-digit plan number, plan effective date, and plan-characteristic codes match the prior year's filing.
- Reconcile contributions, rollovers, and distributions on the plan ledger to provider statements and to the sponsor's payroll records.
- Confirm EFAST2 signer ID and PIN are active for both the plan administrator and the preparer. Re-issue any expired credentials.
- Tie the year-end asset total on Part III to the supporting valuation file, including participant loan balances and illiquid valuations.
- Cross-check that no non-owner W-2 employee became a plan participant on the first day of the plan year. If so, the plan moves to Form 5500-SF or Form 5500 starting that plan year.
- Confirm whether Form 8955-SSA is required for any separated participant with a deferred vested benefit, and file it separately from the 5500-EZ.
- If the sponsor needs more time, file Form 5558 by the original due date and store the proof of submission in the plan file.
- Have the plan administrator or sponsor sign the return under penalties of perjury, then submit through EFAST2 and save the electronic acceptance plus the signed copy in a dated folder.
Rev. Proc. 2015-32 late-filer relief packet
- Confirm no CP 283 Notice has been issued for any of the delinquent plan years. If one has, the program is unavailable for that year and the path is reasonable-cause abatement instead.
- Pull the form revision of Form 5500-EZ in effect for each delinquent plan year. Do not use the current-year form for prior years.
- Complete one full Form 5500-EZ per delinquent year, including all line items for that year's revision.
- Attach Form 14704 as the cover transmittal, listing every delinquent year being submitted under the program.
- Calculate the fee at $500 per delinquent return, capped at $1,500 per plan, and include a single check payable to the United States Treasury.
- Mail the package as paper to the IRS address specified in the Rev. Proc. 2015-32 instructions, and retain certified-mail proof of delivery.
- Document the submission date and the expected IRS confirmation window in the plan file, and flag the sponsor to keep the next cycle's return on the standard July 31 timeline.
Keep 5500 Season From Stalling
The Form 5500-EZ cycle has a delivery quirk that most firms underestimate: the July 31 calendar-year deadline lands while staff are still wrapping S-Corp and partnership extension work, and the filing itself depends on year-end asset values that often need valuation support for participant loans, real estate, or private notes. When that prep gets pushed, the late-filing exposure is steep, $250 per day up to $150,000 per plan year under IRC §6652(e) as raised by the SECURE Act of 2019, and the preventive relief lane under Rev. Proc. 2015-32 caps at $1,500 per plan only when used before a CP 283 Notice issues.
The fix is not "work faster in July." It is a year-round, plan-by-plan reporting discipline that pulls the aggregate-asset test, the asset reconciliation, and the EFAST2 credentials forward into a known cadence so July becomes signature day, not scramble day.
- Run the aggregate $250,000 test in January using December 31 values across every one-participant plan of the sponsor, include outstanding participant loans, and flag near-threshold sponsors for continued filing.
- Re-issue EFAST2 signer IDs and PINs by mid-May for every plan administrator and preparer the firm represents, so credential recovery does not eat the last week of July.
- Standardize the Part III asset-reconciliation workpaper to tie each line to a source (provider statement, valuation memo, loan amortization schedule) and lock it into review by June 15.
- Build a plan-termination intake trigger so any sponsor distributing the last dollar that year gets a final 5500-EZ scheduled regardless of asset size, with the "final return" box queued for Part I.
- Maintain a separate Rev. Proc. 2015-32 packet template (per-year revisions of Form 5500-EZ plus a Form 14704 cover) so late-filer cleanup is a known SOP rather than a research project.
This is the layer Accountably builds into a sponsor's plan-reporting workflow: documented SOPs for the aggregation test, the EFAST2 submission, and the late-filer cleanup, with U.S.-led review on every package before it ships. See taxation services for how that integrates with the rest of the season's filings.
FAQs
What is Form 5500-EZ
It is the annual return for one-participant plans and certain foreign plans. You report year-end assets, contributions, rollovers, loans, participant count, and plan characteristics. Filing on time keeps your plan’s compliance record clean and reduces penalty risk.
What is the difference between 5500-EZ and 5500-SF
5500-EZ is for one-participant and certain foreign plans. 5500-SF is for small multi-participant plans. You should no longer substitute 5500-SF for 5500-EZ if you are a one-participant filer.
What is the exact threshold for filing 5500-EZ
File when combined one-participant plan assets exceed $250,000 at plan year end, and always file for the final plan year. Combine all one-participant plans you maintain for this test.
What is the due date for 5500-EZ
Your due date is the last day of the seventh month after the plan year ends, for calendar-year plans that is July 31, and you can extend by 2.5 months using Form 5558 filed by the original due date.
Where do I file if I cannot e-file
If you qualify for a paper exception or have an undue hardship waiver, mail your 5500-EZ to the IRS Ogden, UT address shown on the IRS site. Otherwise, use EFAST2 and keep the acceptance in your records.
How do late filers reduce penalties
Use the IRS late-filer penalty relief program with Form 14704 and paper returns, or request reasonable cause relief. The program uses a fixed fee per delinquent return and a cap per submission for the same plan.