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Not filing will eventually cause more work/headaches than filing with zeros for the financial info. Assuming there are contributions in 2021, are you/they going to use an effective date of 2020 (will make the DOL/IRS think, correctly, that a 2020 return was not filed) or 2021 (wrong)? If they are ever audited and use "2021" as the effective date on the 5500, it will be compared to the date in the doc and cause a problem then too. Just do it.

Even if your client might consider someone else’s advice that an annual report and information return might not be required, your client might consider filing a Form 5500 return desirable because the IRS counts a plan trust’s Federal income tax statute of limitations from that filing. IRS Announcement 2007-63, 2007-30 Internal Revenue Bulletin (July 23, 2007). https://www.irs.gov/irb/2007-30_IRB#ANN-2007-63 When the plan’s administrator files its Form 5500 for 2020, three years later (and, often, practically sooner) 2020 will roll out of the years the IRS would examine. Although an employer might feel there is little risk that the IRS would find an operational defect for 2020, why would an employer/administrator leave open any possibility of being put to the burden of responding to IRS information requests (if it is inexpensive to file the 2020 Form 5500)?

Just blame it on BG5150. My wife does...

I would ask the document provider to weigh in. Some documents are purposely vague and allow a wide window of interpretation. I am not comfortable allocating different rates of match on a discretionary basis. To me, "discretionary match" means it will be made year to year at the Employer's discretion, and that the formula each year is also at the discretion of the ER. But it's either a uniform match or tiered. Not a grouping method similar to profit sharing.