Form 5500, Schedule H and the schedules the auditor reports on

In this lesson you will

Compute the Form 5500 due date and the Form 5558 extension
Identify the Schedule H lines that require attached schedules the auditor reports on
Apply the 5 percent test for reportable transactions
Explain the DOL penalty and rejection consequences of a deficient accountant’s report

Due dates

Form 5500 and all schedules and attachments are due by the last day of the 7th calendar month after the end of the plan year. A one-time extension of up to 2 and one-half months is available by filing IRS Form 5558 on or before the normal due date. If the due date falls on a weekend or federal holiday, the filing may be made the next business day. A calendar-year plan's 2025 return is due July 31, 2026, or October 15, 2026 with the extension. The EBP audit timeline guide works through fiscal-year plans.

What a large plan files

Under 29 CFR 2520.103-1(b), a plan with 100 or more participants files Form 5500 with the applicable schedules, including Schedule H (financial information), Schedule C (service providers), Schedule A (insurance), Schedule G (financial transaction schedules) and Schedule R (retirement plan information), plus the IQPA's report and the audited financial statements. Defined benefit plans add Schedule SB or MB.

The schedules the auditor reports on

29 CFR 2520.103-10 requires separate financial schedules, which become the ERISA-required supplemental schedules covered by the auditor's opinion:

Schedule H line 4i, assets held for investment. One schedule of assets held at year-end, and one of assets acquired and disposed of within the year, showing identity of issue (with a notation if a party in interest), description, cost and current value. 29 CFR 2520.103-11 leaves some items off the acquired-and-disposed schedule, such as mutual fund shares and collective trust units bought and sold within the year. Cost may be omitted for participant-directed investments.
Schedule H line 4j, reportable transactions. A reportable transaction is a single transaction exceeding 5 percent of the current value of plan assets, or a series of transactions (with the same person for non-securities property, or in the same security issue) aggregating more than 5 percent, or any securities transaction with a person if any prior or subsequent single securities transaction with that person within the plan year exceeds 5 percent (29 CFR 2520.103-6). The base is the current value of plan assets at the beginning of the year. Transactions a participant directs in an individual account plan are not reportable on line 4j, though those assets still count in the 5 percent base, so most 401(k) and 403(b) plans have little or nothing to report.
Schedule H line 4a, delinquent participant contributions. Late deferrals and loan repayments are reported for the year they were late and each later year until fully corrected, including lost earnings. They are treated as part of the supplemental schedules for the IQPA opinion.
Schedule G. Loans or fixed income obligations in default (Part I), leases in default (Part II) and nonexempt party-in-interest transactions (Part III).

Line items that trigger audit work

Several Schedule H Part IV questions are compliance flags the auditor reads and tests: line 4a (late contributions), line 4b (loans in default), line 4d (nonexempt transactions), line 4e (fidelity bond) and lines 4i and 4j (schedules attached). Part III, line 3, carries the accountant's opinion information. Answers must agree with the audit evidence. See the Form 5500 financial statement reconciliation.

Penalties and rejection

The DOL may assess up to $2,739 a day against an administrator who fails or refuses to file a complete and accurate report (ERISA section 502(c)(2) and 29 CFR 2575.502c-2, as adjusted for inflation and cited in the 2025 instructions). An annual report with a deficient accountant's report is incomplete. The IRS has its own penalties under the Code.

Common file mistakes

Schedule H line 4i missing the party-in-interest notation for sponsor stock or the trustee's proprietary funds.
Line 4j answered "No" without running the 5 percent test.
Delinquent contributions corrected in the year but omitted from line 4a.
Financial statement totals that do not reconcile to Schedule H with no explanation in the notes.

Use the Form 5500 filing checklist.

Worked example

Orchard Hill Credit Union Pension Plan: due dates and the 5 percent test

Orchard Hill Credit Union Pension Plan, a defined benefit plan whose investments are directed by the trustee, has a calendar plan year. Its 2025 Form 5500 is due July 31, 2026. The administrator files Form 5558 on July 20, 2026, extending the deadline by 2 and one-half months to October 15, 2026. The audit report must be dated, and the substantially complete draft Form 5500 read, before that date.

Reportable transaction test: plan assets at January 1, 2025 were $38,000,000, so the 5 percent threshold is $1,900,000.

Transaction	Amount	Reportable?
Single purchase of a bond fund when the investment committee rebalances	$6,400,000	Yes, single transaction over $1,900,000
40 purchases of an equity index fund through the year	$2,250,000 total	Yes, series in the same security issue over $1,900,000
Single sale of a real estate fund	$1,200,000	Not on its own

The administrator must check "Yes" on line 4j and attach a schedule of reportable transactions showing the two items. Had these been participant-directed trades in a 401(k) plan, none would be reportable. The auditor tests the schedule as an ERISA-required supplemental schedule, including its form and content, and reports on it in relation to the financial statements as a whole.

Self-check

Answer each question before you open the answer.

A plan year ends June 30, 2026. When is the Form 5500 due without an extension, and how long is the extension?
Show answer
January 31, 2027, the last day of the 7th calendar month after year-end. That date is a Sunday, so the filing may be made Monday, February 1, 2027. Form 5558 extends the deadline by up to 2 and one-half months.
Plan assets at the start of the year are $10 million. Is a single trustee-directed $520,000 purchase reportable on line 4j?
Show answer
Yes. A single transaction exceeding 5 percent of the current value of plan assets at the beginning of the year ($500,000) is a reportable transaction.
Late deferrals from 2025 were fully corrected, with lost earnings, in 2025. On which Form 5500s do they appear on line 4a?
Show answer
On the 2025 Form 5500 only. Delinquent contributions are reported for the year they were delinquent and again on each later year’s return until the violation is fully corrected, principal and lost earnings included. Full correction in 2025 means nothing carries to 2026.

Sources

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Standards are paraphrased from the primary sources listed above; read the source before relying on a requirement. This lesson is training material, not professional advice. Report an error