If the total value of your Solo 401(k) reaches $250,000 at any point during the calendar year, yes. A final Form 5500-EZ is also required when you terminate your plan, regardless of plan value.
Form 5500-EZ is an annual informational return filed with the IRS by one-participant retirement plans. It is not a tax return. It reports summary data about your plan including total asset value, contributions, distributions, and any outstanding participant loans. The IRS uses this data to monitor the retirement savings system.
Form 5500-EZ applies to one-participant plans, meaning plans that cover only the business owner, the owner's spouse, business partners, and the spouses of business partners. Plans with non-owner employees are not eligible for Form 5500-EZ.
The filing threshold is $250,000 in total plan assets. The threshold is triggered if plan assets reach that level at any point during the calendar year, not just at year-end. A plan that crosses the threshold mid-year and then declines in value still has a filing obligation for that year.
A final Form 5500-EZ is required whenever a plan is terminated, regardless of plan value at the time of termination.
For calendar-year plans, Form 5500-EZ is due on July 31 of the following year. If July 31 falls on a weekend or holiday, the next business day becomes the deadline for that year.
When a plan is terminated, the plan year ends on the last day of the month of termination. The Form 5500-EZ for a final plan year is due by the end of the seventh month from that date. For example, a plan terminated in September would have a final Form 5500-EZ due by the end of the following April.
Form 5500-EZ can be filed by paper or electronically.
For paper filing, use the fillable PDF available on the IRS website and mail it to the IRS. The form is updated annually, so confirm you are using the version for the correct plan year.
For electronic filing, use the EFAST2 system. Note that filers who are required to file 10 or more returns of any type with the IRS during the calendar year must file Form 5500-EZ electronically. Paper filing is not accepted for those filers. Set up your EFAST2 account well in advance of the deadline.
Plan value for Form 5500-EZ purposes is the total fair market value of all assets held across the plan as of December 31, including all participant sub-accounts. Include cash, real estate, private placements, cryptocurrency, promissory notes, and outstanding participant loan balances.
For assets like cryptocurrency or brokerage holdings, use the exchange or account value as of December 31. For real estate, realtor comparables are generally acceptable unless a taxable event such as a Roth conversion or in-kind distribution is involved. For promissory notes, use the open principal balance plus accrued unpaid interest.
When completing Form 5500-EZ, the following characteristic codes apply to a standard Solo 401(k):
The IRS assesses a penalty of $250 per day for failure to file Form 5500-EZ, up to $150,000 per plan year. Late filers may be eligible for penalty relief under Revenue Procedure 2015-32. If you have missed a filing deadline, consult your CPA before attempting to file late.
Can I file Form 5500-EZ myself?
Yes. Many Solo 401(k) owners prepare and file it themselves, particularly when the plan holds straightforward assets. Others use a CPA. If your CPA is not familiar with the form, ask for a referral to someone who is.
What if my plan value dropped below $250,000 before year-end?
The filing obligation still applies. A plan that was above $250,000 at any time during the year must file, even if the year-end value is lower.
Do I need to file if my plan has no activity during the year?
If the plan value exceeded $250,000 at any point during the year, yes. Inactivity does not eliminate the filing obligation.
Should I try to keep my plan under $250,000 to avoid filing?
No. Form 5500-EZ is a straightforward informational return, and avoiding it is not a meaningful reason to limit your plan's growth. There may be legitimate reasons to balance capital allocations across multiple retirement accounts in your name, but keeping a Solo 401(k) below the filing threshold should not be one of them.
This information is provided for educational purposes only and should not be interpreted as tax, legal, or investment advice. Readers are encouraged to consult a qualified professional who can offer guidance based on their personal situation.