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Two Months until the 401(k) Filing Deadline, and You Haven’t Started Yet?

by | Aug 13, 2025

If you’re a 401(k) plan sponsor and it’s August, the October 15 Form 5500 deadline is already looming. Normally, I’d be telling you to make sure your auditor is wrapping up fieldwork by now.

But some of you reading this haven’t even found an auditor yet. Maybe you thought your TPA handled it. Maybe you didn’t find out until recently your plan crossed the threshold. Or maybe an engagement letter’s still sitting unsigned in your inbox.

Whatever the reason, here’s the hard truth: If you haven’t already started working with a 401(k) auditor, the clock is already working against you.

The “Normal” 401(k) Audit Timeline

For a large plan audit done right:

  • May–June: Engagement letter signed, document requests sent.
  • July–August: Fieldwork testing.
  • September: Draft financial statements issued, reviewed, finalized.
  • Early October: Final audit report delivered, Form 5500 filed.

The “It’s August and We Don’t Have a 401(k) Auditor Yet” Timeline

If you’re starting in mid-August, here’s what your reality looks like:

Man working on phone

Week 1 (This Week):

  • Identify and hire an ERISA-experienced auditor immediately.
  • Sign the engagement letter within 24–48 hours.
  • Send all required documents within days, not weeks.

Week 2–3:

  • Auditor begins fieldwork at a sprint—no long pauses, no “we’ll get to it.”
  • Expect daily document requests; respond same-day.

Late August–Early September:

  • Fieldwork wraps up if everyone’s moving fast.
  • Draft financial statements issued ASAP.
  • TPA starts finalizing the Form 5500.

Mid–Late September:

  • Resolve all findings, corrections, and questions quickly.
  • Final audit report delivered.

Early October:

  • Sign off, file Form 5500 before October 15.

This schedule leaves zero margin for error. A single delay can push you past the deadline.

What Happens if You Miss October 15?

The IRS penalty is $25/day (up to $15,000). The DOL penalty is $2,529/day with no cap. These aren’t theoretical, they are enforced.

What You Need to Do Right Now

If you don’t have an auditor:

But here’s some good news: despite starting so late, you shouldn’t be forced into paying outrageous rush fees or inflated “emergency” pricing. There are firms like PriceKubecka that can start your audit today and still have you filed well before the October 15 deadline.

Our fully automated audit process means we can work fast—without cutting corners—while offering a fixed flat fee well below the national average. Even this late in the game, your audit shouldn’t cost more than $15,000.

401(k) Audit Bottom Line

If you’re still auditor-shopping in August, you’re on a crash-course timeline. It’s doable, but only if you act right now. Every day you wait shaves off precious audit time, and October 15 isn’t moving for you.

But acting now doesn’t have to mean overpaying. PriceKubecka has the capacity to start immediately, leverage technology to get you across the finish line, and charge a flat, reasonable fee. Don’t settle for panic pricing when you can get an on-time, compliant, and cost-efficient 401(k) audit starting today. Please CONTACT US  to get started. 

Frequently Asked Questions

What should I do if I missed the October 15 Form 5500 deadline?

First, confirm that October 15 was actually your plan’s deadline and that a valid extension applied. If the deadline has passed, determine what is preventing the Form 5500 from being completed. If a required 401(k) audit is unfinished or hasn’t started, contact an experienced employee benefit plan auditor immediately and work with your other advisors to determine the appropriate filing and penalty-relief options.

Can you file Form 5500 after the deadline?

Yes. A delinquent Form 5500 can still be filed after its due date. Filing late does not eliminate the filing requirement, however, and potential DOL and IRS penalties may apply. Eligible plan administrators may be able to use the DOL’s Delinquent Filer Voluntary Compliance Program to reduce certain penalties.

What are the penalties for filing Form 5500 late?

The Department of Labor may assess substantial civil penalties for failure to file a complete and accurate Form 5500. Current Form 5500 instructions state a potential DOL penalty of up to $2,739 per day. The IRS can separately assess $250 per day, up to $150,000 per plan year, for certain late Form 5500-series filings. Actual penalties and available relief depend on the circumstances.

What is the DOL's Delinquent Filer Voluntary Compliance Program?

The DFVCP is a Department of Labor program that allows qualifying plan administrators to voluntarily submit delinquent Form 5500 filings and pay reduced civil penalties. Eligibility generally requires correcting the filing before the DOL has provided written notice of the failure to file.

What if my 401(k) audit hasn't started and the Form 5500 deadline has already passed?

If your plan is required to have an independent audit, missing the Form 5500 deadline does not remove that requirement. Contact an employee benefit plan auditor as soon as possible, explain that the filing is already late and determine what records are needed to begin the audit immediately. Work simultaneously with your TPA and other advisors to address the delinquent filing and determine whether penalty-relief options are available.

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