Fixing Problems with Electronic Signatures for 5500 Series Returns

 

A plan sponsor/employer or the plan administrator must electronically sign Forms 5500 and 5500-SF before submitting the returns. The forms may be signed by an authorized plan service provider using the additional “e-signature option.” The electronic filing system will reject forms not properly signed, potentially resulting in penalties for the plan.

Starting January 1, 2013, Forms 5500 and 5500-SF that have a missing or invalid  electronic signature will receive a filing status of “unprocessable.”

When is an electronic signature valid?

Any individual who e-signs an original or amended return must have a valid EFAST2 User ID and PIN. See the EFAST2 Credentials FAQ for questions and answers regarding EFAST2-issued UserIDs and PINs.

Authorized Service Providers e-signing new or amended forms must:

  • have specific written authorization from the plan administrator,
  • have the plan administrator manually sign a paper copy of the completed new or amended form, and
  • attach a PDF copy of the manually signed new or amended form to the filing (DOL will include the image of the manual signature in their online database.)

Check the return’s filing status and make signature corrections

After submitting the form, check its filing status for error messages. If the filing status is "Unprocessable,” electronically sign and re-submit the original filing.

Amending returns

Follow the Frequently Asked Questions about EFAST2 to electronically amend a previously filed return. Keep a copy of the manually signed Form 5500 or 5500-SF for the plan’s records.

Additional Resources

  • Instructions for Form 5500 series returns, including Form 5500-SF, Short Form Annual Return/Report of Small Employee Benefit Plan
  • EFAST FAQs, including Qs on electronic signature requirements