The DFVCP charges $10 a day and caps the total at $750 or $2,000 per filing.
Under the Delinquent Filer Voluntary Compliance Program the penalty is $10 a day, capped by plan size and by number of years late.
How the program prices a late filing.
$10 a Day
The DFVCP charges $10 for each day the form is late.
Small Plans
Plans with fewer than 100 participants are capped at $750 per filing and $1,500 per plan.
Large Plans
Plans with 100 or more participants are capped at $2,000 per filing and $4,000 per plan.
Where the numbers differ.
501(c)(3) Small Plans
Small plans sponsored by tax-exempt organizations have a flat $750 cap per plan.
Multiple Years
The per-plan caps apply when several years are late, so the cost does not multiply without limit.
Compare to the DOL
The DOL penalty can reach $2,739 a day with no cap, so the voluntary program is far cheaper.
Pay Online
The program fee is paid with the filing through the DOL system.
Quick answers.
Short answers. This is general information, not legal or tax advice.
Is the program free?
No. There is a fixed per-day charge, but it is capped.
Who can use it?
Plan administrators who have not received a delinquency notice from the DOL.
Does it cover the IRS?
It addresses the DOL penalty. Retirement plans may separately owe the IRS penalty.
Where the rules and figures come from.
Each figure on this page comes from the source below. Amounts are indexed or updated over time, so confirm current figures before relying on them.
29 U.S.C. 1132
ERISA Section 502(c)(2): civil penalty for failure to file the annual report.
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The renewal letter
Your current plan summary
Contribution split by tier
Enrolled counts by tier
Four documents — two more if your group is 50 or more. Nothing else; every extra one is a reason to postpone.
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