Check 2025 combined assets, final-year status and electronic filing before July 31, 2026. Preserve the records and responsibilities behind an owner-only plan.
July 6, 2026 · Financial Forte Staff
Historical article: prepared retrospectively using information available as of July 6, 2026.
An owner-only retirement plan can be simpler than a plan covering a larger workforce, but the word “solo” does not remove the paperwork. Contributions, account values, plan documents and annual filing obligations still need attention. The owner remains responsible for making sure the arrangement operates as intended.
Use the annual review to confirm both the plan's current status and what changed during the year. For a calendar-year plan reviewing 2025 records in July 2026, the filing question includes the combined assets of the employer's one-participant plans, whether a plan ended and whether the filing must be electronic. A custodian statement alone does not answer all three.
Confirm that the plan still fits the category
Form 5500-EZ has a specific one-participant-plan definition that can include an owner and spouse, or partners and their spouses, under the stated ownership and participation conditions. It is not simply any retirement plan with one active saver. Hiring an employee or changing ownership can require a fresh eligibility and reporting review.[1]
Give the administrator a complete census, including employees who work part time, spouses on payroll and people employed by related businesses. Do not decide that a newly hired person is irrelevant because they have not yet joined the plan. Service history and plan entry rules determine when eligibility becomes an issue, and long-term part-time rules can matter.[2]
An owner-only arrangement generally is not subject to the same ERISA Title I framework as a plan covering common-law employees. That distinction should be determined from the actual facts. It does not excuse tax qualification, contribution, reporting or document obligations, and the analysis can change when eligible employees enter the picture.[1][3]
Apply the asset exception across the employer's plans
For the 2025 plan year, the Form 5500-EZ instructions generally provide an exception from filing when combined year-end assets of the employer's one-participant plans do not exceed $250,000, unless it is a final plan year. If the combined amount exceeds that threshold, each applicable one-participant plan must file, including one whose own assets are below $250,000.[1]
Suppose an owner’s one-participant 401(k) has $215,000 at the end of 2025 and whose separate one-participant defined benefit plan has $85,000. Assume both plans meet the relevant definition and belong in the same employer's aggregation. Combined assets are $300,000 ($215,000 plus $85,000), which exceeds $250,000 by $50,000.
Reviewing only the 401(k) statement would produce the wrong conclusion. Neither plan individually exceeds $250,000, yet the combined test requires a filing for each under these assumptions. The defined benefit plan also has actuarial and funding work that does not disappear because Form 5500-EZ is a shorter return.
Now consider a different owner closing a plan with $90,000 in assets. A final return is generally required for the final plan year even though assets are below the usual exception threshold. Confirm when all assets have actually been distributed or transferred and all liabilities satisfied; deciding to terminate is not necessarily the same as completing the final year.[1]
Verify the deadline and the filing method
The normal due date is the last day of the seventh month after the plan year ends. For a calendar-year 2025 plan, that generally means July 31, 2026, absent an applicable extension or relief. An available extension must be evaluated and handled under the instructions; do not assume the business income tax extension automatically resolves every plan filing question.[1]
Electronic filing is a separate determination. The 2025 instructions generally require Form 5500-EZ to be filed through EFAST2 when the filer is required to file at least ten returns of any type with the IRS during the calendar year containing the first day of the plan year. That count can include information, income, employment and excise tax returns. It is not a count of retirement-plan returns alone.[1]
For example, a hypothetical filer required to submit six information returns, four employment tax returns and one income tax return has 11 counted returns (six plus four plus one), assuming all belong in the applicable calculation. The owner should have the tax preparer verify the actual categories and period, then confirm the administrator uses the required filing method.
Keep proof of submission and any acceptance or error notices, and assign someone to resolve a rejection promptly. A prepared form sitting in a shared folder is not evidence it was filed. If a filing problem is discovered, obtain advice about the appropriate correction or relief process rather than simply treating a late submission as an ordinary on-time return.
Preserve the records behind the return
Reconcile contributions with compensation and the plan's formula. For a self-employed owner, earned-income calculations can require adjustments that differ from a corporate employee's W-2 calculation. A transfer into the account is not, by itself, proof of a permissible deductible contribution. Have the tax preparer and administrator coordinate the calculation.[4]
Retain plan documents, amendments, elections, account valuations, contribution records, distribution records and prior filings. If there are unusual assets, confirm how year-end values were established. For a defined benefit plan, preserve the actuarial valuation and required funding records even when related schedules are retained rather than attached to Form 5500-EZ.[1]
Assign one person to collect the records and another qualified party to review the relevant calculations, where practical. That modest process can reduce missed filings and prevent a change in staffing or ownership from going unnoticed. It also makes the next year's review less dependent on memory.
Before July ends, ask for a written answer to four questions: which plans are included, what were their combined year-end assets, is any return final and how will each required filing be submitted? Those answers turn “owner-only” into a manageable administrative process instead of an assumption that nothing needs to be done.
Related reading
- Form 5500 or 5500-EZ: What Your Business Needs to Check
- Before You Sign Form 5500, Ask These Operational Questions
Have more questions about owner-only retirement plans and annual reporting? Email Dave at dave@financialforte.com to discuss your questions and next steps.
The contact invitation is current; it does not imply this contact path existed on the historical reference date.
Educational information, not personalized investment, tax, legal or benefits advice. Examples use hypothetical assumptions. Verify current rules and your circumstances before acting.
Sources
- [1] IRS Instructions for Form 5500-EZ (2025) — July 7, 2025 printed revision, 2025 edition; search title incorrectly labels 2024
- [2] IRS Notice 2024-73: Long-term, part-time employee guidance — Released October 3, 2024; applicable plan years after December 31, 2024
- [3] 29 U.S.C. 1003: ERISA coverage — 2023 Code
- [4] IRS Publication 560: Retirement Plans for Small Business — July 5, 2024; printed date and PDF metadata verified

