2025 IRS form 5330 - paper filing?

Interesting situation here. A new plan in 2025. Long story short, they withheld deferrals from many payrolls and did not submit. They have since submitted, using DOL calculator for interest, and will file with the DOL under VFC program. As part of the VFC filing, they will submit a copy of the 5330 proving payment of the interest.

So, must this 2025 5330 filing, for the 2025 year, be submitted electronically? In July of 2025, the IRS said this:

Treas. Reg. 54.6011-3(a) requires a taxpayer to file Form 5330, Return of Excise Taxes Related to Employee Benefit Plans, electronically for taxable years ending on or after December 31, 2023, if the filer is required to file at least 10 returns of any type during the calendar year that the Form 5330 is due. Treas. Reg. 54.6011-3 (b) and Instructions for Form 5330 also provide, on an annual basis, exclusions from electronic filing requirements in cases of undue hardship.

Form 5330 can be filed electronically using the IRS Modernized e-File (MeF) System through an IRS authorized Form 5330 e-file provider. Currently, IRS has only one authorized e-filing provider for the Form 5330. As a result of the lack of authorized e-file providers for the Form 5330, the IRS has determined that a filer is permitted to file a paper Form 5330 for the 2024 taxable year. The filer should document that the reason for not filing electronically and filing a paper Form 5330 is the lack of authorized vendors.

Seems to me that since this 5330 is being filed under the same timeframe and basic circumstances, that this waiver should prove valid and allow paper filing. Thoughts? Thanks.

Here's the "Form 5330 Corner" page on the IRS website -- does anything here help?

https://www.irs.gov/retirement-plans/form-5330-corner

Despite the list of authorized providers we just filed a 5330 electronically using FT Williams (although I guess it could have been via the government's system)  a couple of weeks ago.  I just made sure I liked the numbers and passed it on to someone here who knew how to do it but I am sure it was electronic.  

I believe it was agreed we could have done paper but we did file electronically.  It was for a PYE 2024 ESOP.   

Thanks Lois - I had looked at this before asking the question. Didn't seem to answer my specific question.

Thanks ESOP.