ERISA plans are required to file Form 5500 if 100 or more are enrolled in the plan and are unfunded/insured (a combination of insured and funded still qualifies for the small group exemption from this filing requirement). This form satisfies information reporting to the Department of Labor and IRS. Notice 2020-23 extended filing deadlines for some plans.
- Form 5500 typically due seven (7) months after the end of the plan year.
- Due to Covid-19, deadlines April 15- July 15 are postponed three (3) months, similar to personal income tax delays.
- For example, a plan with a June 30th plan year end will have a July 15th deadline to file rather than the normal April 15th deadline (representing the January 31st deadline plus an additional 2 ½ month extension, if applied for).
Guidance is welcome in hopes that, similarly, it will extend other Form 5500 deadlines. Calendar year plans and all plans with a due date that does not fall between April 15 and July 15 have their normal deadlines at the time of this writing. For calendar year plans, without an extension, that deadline is July 31st.
HSA contributions due date for calendar year plans extended from April 15, 2020 to July 15, 2020.
- Delay granted in FAQs.