Form 5500 Filing - Late Adoption of a Plan

We have a plan that was adopted after the extension deadline (as per Secure Act), so there was no extension filed.  

How do we mark that on the Form 5500.  I'm getting an error when I click off:

"If this is a retroactively adopted plan permitted by SECURE Act section 201, check here"

Is that the right way to indicate it on the Form 5500?

That box is checked if you adopt after year end. For the extended deadline...

Presumably the plan sponsor tax return is on extension or you couldn't do it anyway and you rely on that for automatic approval of extension assuming plan year and tax year are the same but that extended deadline might be 9/15 or 10/15 depending on entity type of the sponsor. 

Have you checked the instructions for Form 5500? it may be in there, I'm not sure. 

It is possible that you are clicking on something and getting an error message because of how the software vendor is editing your entries.  Are you using EFAST2-approved vendor software or IFILE?  If you are using a vendor, then I suggest calling their support group.  They may have implemented edits beyond what is required by EFAST2 that are giving you the error message, and your issue may have to do with their edits and have nothing to do with the form or instructions.

I've worked with multiple vendors and marvel at how well their systems handle the complexities of 5500s. but they, like us, are not perfect.

15 hours ago, C. B. Zeller said:

To put some dates on the original question ... am I understanding it correctly, that you are talking about a plan adopted (say) 8/15/2025 with an initial effective plan year of 1/1/2024-12/31/2024?

If that's the case, the first Form 5500 will be the 2025 form, due 7/31/2026 or 10/15/2026 on extension. You will check the box for a retroactively adopted plan on the 2025 form. You do not file a 2024 Form 5500 at all. However you will need to attach both the 2024 and 2025 Schedule SB to the 2025 filing.

Great, thank you!

What if it is a 1-person plan where the SB isn't required.  Is it still just that the first Form 5500 is filed for year 2 since the plan was retroactively adopted?

You would file the 2025 5500-EZ and check the retroactive adoption box.

Of course an SB is still required to be provided to the plan sponsor, it just doesn't need to be attached or filed with the 5500-EZ.

10 minutes ago, C. B. Zeller said:

You would file the 2025 5500-EZ and check the retroactive adoption box.

Of course an SB is still required to be provided to the plan sponsor, it just doesn't need to be attached or filed with the 5500-EZ.

Great, thank you!