What Do 2024 Form 5500 Filings Report About Late 401(k) Contributions?
Form 5500 filings can show that a plan reported delinquent participant contributions, but they cannot tell a reader how often late deposits actually occur across every U.S. 401(k). This page sets out what the 2024 Schedule H filing record reports, what that reporting item includes, and the limits that travel with every figure.
Educational only: This page reports filing-level statistics from named primary sources. It says nothing about any individual plan and is not financial, tax or legal advice.
25.14% of eligible 401(k)-type Schedule H plan filings for plan years ending in 2024 — 13,528 of 53,806 filings — affirmatively reported line 4a.
DOL EBSA 2024 Latest research files; file vintage 2026-09-25, extracted 2026-10-22. S2 S3
Key takeaways
- The unit is plan filings, never employers, plans, people, participants or accounts. S2
- Rates run from 23.20% (447 / 1,927) below 100 to 28.72% (712 / 2,479) at 5,000+, with four UNKNOWN size filings. S2
- The largest 135 filings account for 40.4%; the largest 1,352 account for 77.1%. S2
- The exact median is $33,882.50, or $33,883 rounded; reported amounts are not participant losses. S1
A verified summary of the figures on this page, not the complete filing-level dataset. The underlying Form 5500 and Schedule H research files are linked in Sources.
What Do the Filings Show?
Schedule H is the financial-information schedule generally filed by larger plans. The extraction uses the as-filed population, with file vintage 25 September 2026 and extraction date 22 October 2026. S2 S3
Schedule H coverage is 53,806 of 85,678 eligible filings, or 62.8%; coverage below 100 participants is 6.1%. This is a large-plan Schedule H-filer measure, never a measure of all U.S. 401(k) plans. S2
That skew is a matter of design rather than sampling. Schedule H is the financial-information schedule that larger plans file, while a plan covering fewer than 100 participants at the start of the plan year generally reports on the simplified Form 5500-SF or on Schedule I instead. S1
Almost every plan in the largest size bands therefore appears here, and only a small minority of the smallest plans do.
Reading the headline as a national rate would overstate what the record supports. It describes the filings actually in front of the reader, and those filings lean heavily toward large plans.
That coverage split changes how the headline should be read. Most filings in the 100–499, 500–4,999 and 5,000+ bands use Schedule H, while most filings below 100 participants use a different reporting route. The headline therefore describes a population weighted toward larger filing plans. S2 S3
The denominator also is not a count of entities. A filing is a return for a plan year, and the same plan can submit a return in consecutive years. The analysis deliberately reports the filing record as filed rather than trying to convert it into employers, people or accounts. S2
What Does “Late” Actually Mean Here?
The timing rule concerns when participant contributions become plan assets. For plans with fewer than 100 participants, the regulation supplies a seven-business-day safe harbour at 29 CFR 2510.3-102(a)(2). S1
A plan filing is not an adjudication. A carryover can persist, so reporting frequency is not actual violation incidence. S1
The governing standard is that participant contributions become plan assets as of the earliest date on which they can reasonably be segregated from the employer’s general assets. S1
There is no single universal deadline that applies to every plan, which is the most common misunderstanding readers bring to this subject. What counts as timely depends on what that employer could reasonably have done.
Carryover reporting matters just as much to the count. The instructions require a delinquent amount to be reported again on line 4a in each subsequent year until the year after the violation has been fully corrected. S1
One underlying item can therefore appear across consecutive filings, so the total is a count of filings reporting the condition rather than a count of new events.
Correction status is absent from the research file in either direction. The breakdown between corrected and uncorrected amounts sits on an attached schedule that is not published in the dataset, so nothing here shows whether a given amount was repaid. S2
The general timing standard is the earliest date on which the contributions can reasonably be segregated from the employer’s general assets. That fact-specific standard is why there is no single universal deposit deadline for every plan and payroll arrangement. S1
For a small plan, a deposit made within seven business days is deemed timely under the safe harbour. Large plans do not receive the same bright-line rule, so an identical delay can be timely for one filing population and delinquent for another; that is a rules difference, not evidence of different behaviour. S1
Carryover reporting also means one underlying item can appear on consecutive returns until the year after full correction. The research file has no correction-status field, so it cannot show how many reported amounts were corrected, pending correction or uncorrected. S1
How Does Reporting Vary by Reported Plan Size?
23.20% 447 of 1,927 filings
Four filings are separately UNKNOWN for the size field.
23.38% 7,654 of 32,735 filings
The largest eligible filing band.
28.30% 4,715 of 16,661 filings
A reporting measure, not a compliance comparison.
28.72% 712 of 2,479 filings
The highest rate among these four bands.
Two documented mechanisms sit behind that gradient before behaviour is even in question. A large plan must generally have an independent qualified public accountant examine the plan, and line 4a amounts fall within that examination’s scope. S1
An audited plan has a professional actively looking for late deposits; an unaudited plan does not. Detection differs first.
The second mechanism is the safe harbour itself. Because only plans under 100 participants have the seven-business-day window, an identical delay can be timely for a small plan and delinquent for a larger one. S1
That is a difference in the rules each plan is measured against, not evidence that larger employers handle deferrals worse.
| Reported size band | Reported | Eligible filings | Rate |
|---|---|---|---|
| Under 100 | 447 | 1,927 | 23.20% |
| 100–499 | 7,654 | 32,735 | 23.38% |
| 500–4,999 | 4,715 | 16,661 | 28.30% |
| 5,000+ | 712 | 2,479 | 28.72% |
Large plans generally require an independent qualified public accountant audit, and reported line 4a amounts sit within the auditor’s scope. That means detection can differ before the underlying conduct is even in question. S1
The small-plan safe harbour adds a second reason to avoid a compliance reading of the chart. Reporting rates combine the governing timing rule, audit and review process, payroll scale, and what a filer discloses; they do not isolate employer conduct. S1
The four filings without a usable participant-count field remain separate from the displayed bands. They do not change the reported numerator, but treating missing size as a small-plan count would assert a fact the filing does not provide. S2 S3
How Concentrated Are the Reported Amounts?
The aggregate reported amount is $3,791,499,570, provided only as context. The exact linear-interpolation median is $33,882.50, presented as $33,883 when rounded to a whole dollar. S2
The gap between that median and the much larger mean is the whole shape of the distribution in one comparison. Most reported amounts are modest, and a thin tail of very large ones carries most of the dollars. S2
This describes the spread of reported amounts, not the seriousness of any filing. A large reported figure at a large plan and a small one elsewhere are both simply amounts disclosed on a return.
Floor of 1% of the positive-amount filing count.
Floor of 10% of the positive-amount filing count.
The median and the top-k shares describe the shape of the reported-amount distribution. A median gives the midpoint filing in that distribution, while the concentration shares show how strongly the upper tail contributes to the aggregate; neither measure establishes severity for a participant. S2
The top-1% count uses the stated floor rule because one percent of the reporting filings is not a whole number. The top-10% count follows the same floor convention, making the cutoff visible instead of implying an exact fractional filing. S2
These reported amounts may include prior-year carryovers and, for some filers, late participant-loan repayments. They should not be added across years or translated into damages, restitution, unpaid balances or participant losses. S1
What Can This Measure Not Say?
There are 13,528 affirmative flags and 13,529 positive amounts. Eight duplicate EIN-plus-plan-number pairs yield a 25.15% deduplicated sensitivity, while the headline keeps the verified as-filed result. S2
Differences by reported size are not a finding about employer behavior. Audit requirements, the under-100 safe harbour, correction and filing practices can all affect what reaches the reporting field. S1
The unit deserves one further note. Eight duplicate employer-identification and plan-number pairs mean a small number of plan years appear twice in the as-filed population. S2
Collapsing them moves the headline by a hundredth of a percentage point and leaves the median and concentration untouched, which is why the verified as-filed figure stands and the unit remains plan filings.
The denominator carries its own limit. A plan that received no participant contributions during the year answers the same way as a plan that forwarded every contribution on time, so the share is an as-filed reporting measure rather than an incidence rate. S1
The filing and filer are different units. The eight duplicate EIN-plus-plan-number pairs barely move the share, but the sensitivity is disclosed to show that the headline is an as-filed result rather than a claim to have counted unique entities. S2
Some denominator filings may have received no participant contributions at all during the year and still answer “No.” The research file does not identify the subset with an opportunity for a late transmittal, so the reporting share cannot be converted into an incidence rate. S1
Correction status is absent in either direction: a reported amount may have been fully corrected, pending correction or not corrected, and the research file does not distinguish those cases. That missing field is why this page does not label reported amounts as outstanding or otherwise assign a current status. S1
How Can a Participant Check Their Own Plan?
The EFAST2 search can identify a plan’s public filing, but it cannot settle what happened in a particular account. Begin with the administrator, state the contribution period and payroll information at issue, and retain the response. S4
EBSA provides a route for questions and concerns about employee benefit plans. This page does not determine whether any filing entry applies to a particular account. S5
It is worth being precise about what a line 4a entry can tell an individual. The figure is a plan-level aggregate for the year, so it does not identify which participants were affected, which pay periods were involved, or how much any one account was owed. S2
A plan may also answer affirmatively because of an item already corrected, with the contributions deposited and lost earnings reimbursed.
What the entry does provide is a documented starting point for a specific question to the administrator, which is a stronger position than a general concern.
Line 4a is a plan-level aggregate. It can show that the filing disclosed a reportable condition, but it does not identify an individual participant, payroll date, contribution source or correction status. S1
That distinction makes the administrator the appropriate first source for an account-specific question. Ask for the plan’s explanation and records relevant to the dates at issue, rather than treating a public aggregate as proof about a particular deposit. S4
If the response does not resolve the concern, EBSA’s participant-assistance service can explain available next steps. Its role is distinct from this statistical page, which reports a filing population and cannot adjudicate an individual account. S5
Methodology and Limitations
Population and definitions
Eligible observations are 401(k)-type Schedule H filings for plan years ending in 2024. The numerator is affirmative line 4a flags and the denominator is 53,806 eligible filings. The unit is plan filings only.
Amounts and limitations
Positive reported amounts support the distribution. Top-k uses floor rules: 135 for 1% and 1,352 for 10%. These files are not a census of all U.S. plans; reporting includes carryovers and corrected items.
Supporting files
The verified summary CSV and methodology notes preserve the checked values.
Frequently Asked Questions
What does 25.14% measure?
It is the share of 53,806 eligible 401(k)-type Schedule H filings for plan years ending in 2024 that affirmatively reported line 4a. It is a filing-level reporting measure, not an estimate of all U.S. plans or actual violation incidence.
Does a line 4a report prove current misconduct?
No. A delinquent amount can be carried forward until fully corrected and remains reportable after correction. A report can therefore include a prior-year carryover or a corrected item.
Can line 4a include loan repayments?
Yes. At the filer’s election, line 4a may include delinquent participant-loan repayments. This page does not separate them from other late participant contributions.
Why are the size-band rates different?
The filings show different reporting prevalence by reported participant-count band. Mandatory IQPA audits for large plans and the small-plan seven-business-day safe harbour can affect reporting and detection, so the difference does not prove employer-compliance differences.
Are the reported dollars participant losses?
No. The aggregate is an amount reported on filings. It is not a measure of participant losses, damages, restitution, or an unpaid account balance.
Sources
All sources are government publications or government data services and were available when reviewed on 22 October 2026.
- S1 — U.S. Department of Labor, Employee Benefits Security Administration, “2024 Form 5500 Annual Return/Report Instructions, Schedule H line 4a” (2024)Defines the line 4a reporting item and its treatment of delinquent participant contributions.
- S2 — U.S. Department of Labor, Employee Benefits Security Administration, “2024 Form 5500 Latest Research File: Schedule H” (File vintage 25 September 2026)Primary filing-level source for Schedule H line 4a values and reported amounts.
- S3 — U.S. Department of Labor, Employee Benefits Security Administration, “2024 Form 5500 Latest Research File” (File vintage 25 September 2026)Primary source for population and reported size bands.
- S4 — U.S. Department of Labor, Employee Benefits Security Administration, “Form 5500 Search” (Observed 22 October 2026)Public route to an individual plan’s filings.
- S5 — U.S. Department of Labor, Employee Benefits Security Administration, “Ask EBSA” (Observed 22 October 2026)Participant-assistance route for benefit-plan concerns.
How to Cite This Page
401ktogoldira.org. “What Do 2024 Form 5500 Filings Report About Late 401(k) Contributions?” https://401ktogoldira.org/late-401k-contributions-reported/ (reviewed 22 October 2026).In eligible 2024 401(k)-type Schedule H filings, 13,528 of 53,806 filings (25.14%) affirmatively reported line 4a. This is a filing-level reporting measure, not an estimate of all U.S. 401(k) plans or actual violation incidence; reports may include corrected items, prior-year carryovers and certain late participant-loan repayments.
This page is educational and reports filing-level statistics. It does not evaluate an individual plan or account and is not financial, tax or legal advice.
Reviewed and edited by Daniel M. — Editor, 401kToGoldIRA.org. Last verified: 22 October 2026.
Update History
- October 2026: Initial publication and rebuild into the research-series format, using the verified 2024 filing package.
