The StratEdge Index · Plan years ending in 2023
Form 5500 Late Filing Statistics: On-Time Rates by Plan Size
Only 22.7% of plans with 1,000 or more participants filed by the original federal deadline, versus 59.2% of plans with fewer than 100. Built from 875,610 public Form 5500 and 5500-SF filings for plan years ending in 2023.
· Updated · Data: EFAST2 data as released by DOL in May 2026 (filings received through ). DOL re-released the files on 30 September 2026.
55.0%
Met the original deadline
39.6%
Filed in the extension window
5.4%
Filed after the extended deadline
875,610
Filings, plan years ending in 2023
How the filings arrived
Share of all filings, by receipt date against the original and extended deadlines
Key finding
On-time rates fall as plans grow larger
The largest plans are the least likely to meet the original deadline: only 22.7% of plans with 1,000 or more participants did, versus 59.2% of plans with fewer than 100. Among the largest plans, 69.0% filed in the extension window. The data shows timing by plan size; it does not show why larger plans file later.
Micro (< 100)
730,012 filings
59.2%
Small (100–499)
102,197 filings
38.3%
Mid (500–999)
17,943 filings
27.0%
Large (1,000+)
25,458 filings
22.7%
On-time filing rate by plan size. Source: U.S. Department of Labor EFAST2 Form 5500 and 5500-SF public datasets, plan years ending in 2023 (n = 875,610). EFAST2 data as released by DOL in May 2026.
Form 5500 filing timeliness by plan size
Plan size is the number of participants at the beginning of the plan year, as reported on the filing. Shares are of all filings in each band.
| Participants | Filings | On time | Extension window | After extended deadline |
|---|---|---|---|---|
| Fewer than 100 | 730,012 | 59.2% | 36.2% | 4.6% |
| 100–499 | 102,197 | 38.3% | 52.5% | 9.2% |
| 500–999 | 17,943 | 27.0% | 63.5% | 9.5% |
| 1,000 or more | 25,458 | 22.7% | 69.0% | 8.4% |
| All plans | 875,610 | 55.0% | 39.6% | 5.4% |
Source: U.S. Department of Labor EFAST2 Form 5500 and 5500-SF public datasets, plan years ending in 2023 (n = 875,610). EFAST2 data as released by DOL in May 2026.
Original filings only (amended returns excluded)
| Participants | Original filings | On time | Extension window | After extended deadline |
|---|---|---|---|---|
| Fewer than 100 | 711,783 | 60.3% | 36.6% | 3.1% |
| 100–499 | 94,594 | 40.8% | 54.6% | 4.5% |
| 500–999 | 16,349 | 29.2% | 67.1% | 3.8% |
| 1,000 or more | 23,433 | 24.3% | 72.7% | 3.1% |
| All plans | 846,159 | 56.5% | 40.2% | 3.3% |
29,451 amended returns removed. Source: U.S. Department of Labor EFAST2 Form 5500 and 5500-SF public datasets, plan years ending in 2023 (n = 875,610). EFAST2 data as released by DOL in May 2026.
Download the size-band table (CSV) · counts and shares for all filings and original filings, by plan size
What the after-extended-deadline share does and does not mean
5.4% of all filings (46,925) were received after the extended deadline. Amended returns account for a large part of that figure. In the DOL files used here, an amended return carries the date the amendment was received, not the date of the original filing. Amended returns are 3.4% of all filings but 41.3% of the after-extended-deadline group (19,391 of 46,925).
Excluding amended returns, the after-extended-deadline share falls from 5.4% to 3.3%. The effect is largest for bigger plans: among plans with 100 or more participants, amended returns make up 54.5%–66.4% of filings received after the extended deadline, and the share for 1,000+ participant plans falls from 8.4% to 3.1%.
Some filings counted as after the extended deadline may still have been timely, for example under an IRS disaster-relief postponement or another special extension; this dataset does not identify those cases. Plans that never filed are not in the data at all. Treat the after-extended-deadline share as a measure of receipt timing, not a count of delinquent filers.
Definitions
- Original deadline (on time)
- Received on or before the last day of the seventh month after the plan year ends (31 July 2024 for a calendar-year 2023 plan).
- Extension window
- Received after the original deadline but on or before the 15th day of the tenth month after the plan year ends (15 October 2024 for a calendar-year plan), the date available with a Form 5558 extension. Of filings in the extension window, 96.4% had the Form 5558 indicator checked.
- After the extended deadline
- Received after the 15th day of the tenth month. See the section above for why this is not the same as a late filer count.
Deadline-driven work is what we build for
45.0% of these filings arrived after the original federal deadline. StratEdge gives document-heavy operations one control layer — intake, document tracking, follow-up, and AI assistance — for deadline-driven filing work. Live, with existing customers. Built for credit unions and third-party administrators.
Methodology & data source
Computed from the U.S. Department of Labor EFAST2 Form 5500 and 5500-SF public datasets (2023 "latest" files) as released by DOL in May 2026, with filings received through 24 May 2026. Each filing with a plan year ending in 2023 is classified by its receipt date against the original deadline and the Form 5558 extended deadline defined above. Deadlines are not adjusted for weekends or holidays. All inputs are public; no confidential or customer data is used.
n = 875,610 filings. Plan size uses the participant count at the beginning of the plan year; filings with no count reported are placed in the under-100 band. Extension status is inferred from receipt timing rather than the extension indicator, so results are reproducible from the public files. Audit exposure (16.6% of filings) reflects plans with 100 or more participants, which generally require an independent audit.
Data vintage. DOL re-released the Form 5500 dataset files on 30 September 2026; figures here have not yet been rerun on that release. Counts can change as late and amended filings for 2023 plan years continue to arrive.
Version notes. 2023.2 (4 October 2026): retitled; added the original-filings table, the amended-return breakdown, definitions, data vintage and a CSV download. Figures were rerun on the May 2026 DOL release and are unchanged from the June 2026 edition.
Download the data (CSV) · Band-level aggregates only. Licensed CC BY 4.0; credit the U.S. Department of Labor as the data source.
How to cite
StratEdge Workflow Systems (2026). Form 5500 Late Filing Statistics: On-Time Rates by Plan Size (The StratEdge Index), plan years ending in 2023. Computed from U.S. Department of Labor EFAST2 Form 5500 and 5500-SF public datasets (May 2026 release). https://www.stratedgeworkflow.com/stratedge-index. Accessed [date].