Extensions for Plans Adopted After 12/31

[metsfan026]

We have a few Plans that were adopted in February or March of 2026, as of December 31, 2025 (as allowed under Secure 2.0).  Should we be filing extensions and Form 5500 for these Plans?

I know under Section 201 of Secure 2.0 it technically isn't required, or is that just for Plans adopted after the extension date?

I don't want to miss anything, or file an extension if we aren't supposed to.

Thanks in advance!

[CuseFan]

My understanding is that plans adopted after the end of the year for which they are retroactively effective are not required to file a 5500 for that initial plan year regardless of whether the plan was adopted before or after 7/31 (the 5500 does not ask for the adoption date of a new plan). Could you file an extension and a 5500 for the initial 2025 plan year? Yes, but it is not required. If these are DBPs, remember that a Schedule SB must be prepared for that first year and attached with the second year SB on the that first 5500 filing (or just prepared and provided to plan sponsor if an EZ).

[David D]

It depends on whether your firm plans on filing a 2025 5500 for those plans or not.  I think the industry is split on that as some firms take the position of always filing a 5500 as part of their annual administration cost, and some never file and indicate on the following year return that it was a late adopted plan.