The Department of Labor, Internal Revenue Service, and Pension Benefit Guaranty Corporation have jointly released informational copies of the 2025 Form 5500 series, marking annual updates to the mandatory filing requirements for employee benefit plans. These forms serve as the federal government’s primary tool for monitoring the financial health and operations of retirement and welfare benefit plans across the United States.
The announcement affects thousands of plan administrators who must file annual reports detailing their plans’ financial condition, investment performance, and operational status. For business owners who sponsor employee retirement plans or manage their own Solo 401k arrangements, understanding these regulatory requirements helps ensure compliance and avoid potential penalties.
“Federal regulations require that pension and welfare benefit plans file an annual return/report regarding their financial condition, investments, and operations,” the Department of Labor stated in its December 15 announcement. The agency emphasized that plan administrators should monitor the EFAST2 system for official electronic filing availability rather than using the current informational copies.
Key Changes for 2025 Filing Requirements
The 2025 forms include several notable updates that reflect evolving retirement plan structures and regulatory oversight needs. New plan characteristic codes have been added to better track specific types of retirement arrangements and their operational status.
Form 5500 now includes three new plan characteristic codes—1J, 1K, and 1L—specifically designed to identify multiemployer defined benefit plans that have terminated due to mass withdrawal, plan amendments, or insolvency. These additions provide regulators with more precise data about plan terminations and their underlying causes.
Both Form 5500 and Form 5500-SF will feature a new code 1G for identifying defined benefit plans that use variable annuity benefit formulas. Additionally, existing code 1H on Form 5500 has been clarified to apply exclusively to terminated single-employer plans covered by the Pension Benefit Guaranty Corporation.
Impact on Business Owners and Plan Administrators
These filing requirements primarily affect employers who sponsor retirement plans for their workforce, though the complexity and specific forms required depend on plan size and structure. Small business owners with fewer than 100 plan participants may be eligible to use the simplified Form 5500-SF, while those with very small plans might qualify for the even more streamlined Form 5500-EZ.
The timing of these releases allows plan administrators several months to prepare for the 2025 filing season, which typically begins in the summer following the plan year. The IRS has indicated that paper copies of Form 5500-EZ and its instructions will be available separately on their website after January 1, 2026.
For business owners considering retirement plan options, these regulatory requirements represent one aspect of plan administration costs and complexity. Solo 401k plans, which are designed for self-employed individuals and business owners without employees, may have simplified reporting requirements depending on account balances and contribution levels.
Filing Process and Official Release Timeline
The current release represents informational copies only, and cannot be used for actual 2025 filings. Plan administrators must wait for official electronic versions to become available through the EFAST2 system, which handles electronic filing for Form 5500 series returns.
The Department of Labor advises plan administrators to monitor efast.dol.gov for updates on when official filing systems become operational. Electronic filing is mandatory for most plans, and approved software vendors or direct filing through the EFAST2 website are the only acceptable submission methods.
Questions about the filing process can be directed to the EFAST2 contact center at 866-463-3278 or via email at support@efast.dol.gov. The agencies typically provide additional guidance and clarifications as the filing season approaches.