Our owner-only plans each hold less than the filing threshold. Can we test each account separately?
The usual Form 5500-EZ small-plan filing exception uses a $250,000 combined year-end asset threshold for the employer's one-participant plans, not a…
By AE Tax Advisors Team · Updated October 29, 2026
The usual Form 5500-EZ small-plan filing exception uses a $250,000 combined year-end asset threshold for the employer's one-participant plans, not a separate threshold for each investment account. The current instructions and plan structure determine what must be aggregated. Splitting money among custodians does not create separate filing thresholds.
A specific business-owner situation
An owner has two qualifying plans with assets below the threshold individually but above it together. Looking only at the largest brokerage statement can miss the filing obligation.
Illustrative example, not a client result.
What to establish before filing
- Identify all one-participant plans maintained by the employer.
- Aggregate year-end assets under the instructions.
- Determine each required return and filing method.
Which fact changes the answer?
A different unrelated employer's plan can present a different aggregation question. Establish which employer maintains each plan before totaling balances.
A mistake to avoid
An account is not necessarily a separate plan, and a separate plan is not necessarily a separate threshold.
Records that support the decision
- Plan documents.
- All year-end statements.
- Employer and plan identification records.
The decision to document
Prepare an annual plan inventory and asset test rather than relying on a custodian to know every other account.
Business-owner tax planning and preparation scope · Discuss advisory scope with AE
Related questions
- An employee wants to move a new SIMPLE IRA into a regular IRA. Do the usual rollover rules apply immediately?
- Can our retirement plan pay every fee the business incurs to establish or amend the plan?
Sources and editorial context
- IRS Publication 560: small-business retirement plans
- IRS Form 5500-EZ instructions: one-participant plans
General educational information prepared with AI assistance. No individual professional review is claimed. Apply the relevant tax-year rules to the actual records. Editorial policy · AI disclosure.