ICYMI – some Form 5500 due dates extended

IRS Notice 2020-23 extends the Form 5500 filing deadline for ERISA-covered retirement and welfare plans that have an original or extended filing deadline on or after April 1, 2020, and before July 15, 2020. With this extension, these plans now have until July 15, 2020, to file their Forms 5500.

Plan Year End Original Due Date Normal Extension Request Due Date Relief Due Date
June 30, 2019 N/A April 15, 2020 July 15, 2020
July 31, 2019 N/A May 15, 2020 July 15, 2020
Aug. 31, 2019 N/A June 15, 2020 July 15, 2020
Sept. 30, 2019 April 30, 2020 N/A July 15, 2020
Oct. 31, 2019 May 31, 2020 N/A July 15, 2020
Nov. 30, 2019 June 30, 2020 N/A July 15, 2020

This deadline extension is automatic, which means that plan sponsors do not have to have to call the IRS, file extension forms, or submit other documents to receive this relief. Additional filing extensions must be requested by using Form 5558 by July 15, 2020.

The guidance does not extend the filing deadline for 2019 Form 5500 filings for plans with a December end date, which are still due on July 31, 2020. Employers with such calendar year plans should be prepared to comply with their reporting requirement – or request an extension – by July 31, 2020.

Note: IRS Rev. Proc. 2018-58 provides that any postponement of the Form 5500 filing due date by the IRS (under §7508A) will also be permitted by the Department of Labor and Pension Benefit Guaranty Corporation for similarly situated plan administrators.

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