Tools / Late deposits

Lost earnings on late 401(k) deposits

The Department of Labor’s calculator handles one pay period at a time. Late deposits almost never happen once. Paste the whole schedule.

Interest at the IRC section 6621 underpayment rate in force each quarter, compounded daily, which is the method the Voluntary Fiduciary Correction Program specifies. The figures you type never leave your browser; we see only broad ranges. Privacy.

Your late deposits

One row per pay period: the date the money should have reached the plan, the amount withheld, and the date it actually arrived. Type into the cells, paste rows from a spreadsheet, or upload an .xlsx, .csv or .txt file. The example below is two pay periods; clear it to start your own.

#Should have reached the planAmount withheldActually arrivedDays late
1161
2144
2 pay periods$34,550.00
Lost earnings owed to participants$1,121.14On $34,550.00 of deferrals that reached the plan late, across 2 pay periods. Employer money, not plan assets.
Full program correction

This correction does not clear the self correction route, because lost earnings of $1,121.14 exceed the $1,000 ceiling. It runs through the full Voluntary Fiduciary Correction Program instead, with an application and the retention packet that goes with it.

The correction is not finished when the principal lands. Until both the principal and the lost earnings are paid, each open year is a separate prohibited transaction carrying a 15% excise tax and its own Form 5330, and the amount keeps appearing on the Schedule H supplemental schedule.

One limit on this figure: it covers only the rows above. The $100,000 test that lifts the rate is applied across your whole correction, and crossing it raises the rate on every pay period in the filing, so if this schedule is only part of what you are correcting the figure here can be understated.

Where the interest came from

Each bar runs from the day the money was owed to the day it arrived, split where the quarterly rate changed.
2024-09-13
8%
7%
$592.57
2024-09-30
8%
7%
$528.57

The schedule to keep with the correction

Loss datePrincipalRecovery dateRates appliedLost earnings
2024-09-13$17,240.002025-02-218%, 7% over 161 days$592.57
2024-09-30$17,310.002025-02-218%, 7% over 144 days$528.57
Total$34,550.00$1,121.14

How the Department of Labor method works

Lost earnings approximate what the late money would have earned in the plan. The program fixes the method so every correction is priced the same way:[1]

  1. Start on the loss date, stop on the recovery date. The recovery date is the day the money reached the plan. The loss date depends on how you correct: in a full program application it is the day the plan lost the use of the money, when the withholding could reasonably have been separated from company funds. Under self correction it is the date of withholding itself, normally payday.[1]
  2. Use the IRS underpayment rate for each quarter. The rate is the IRC section 6621(a)(2) underpayment rate in force in each calendar quarter, applied through the factors in IRS Revenue Procedure 95-17, which build in daily compounding.[1][3]
  3. Carry earnings forward each quarter. If the late period crosses a quarter end, the next quarter’s factor applies to the principal plus all earnings so far.[1]
  4. Keep counting if the lost earnings are paid later. Lost earnings paid after the principal carry interest of their own, worked out the same way, up to the day they are paid. If lost earnings and that interest together exceed $100,000, the whole calculation uses the section 6621(c)(1) rates instead, two points higher.[1]

A worked example

A company switches payroll providers in March 2026, and three Friday payrolls of employee deferrals sit in the company account until May 15. It could have separated each one two business days after payday, the same allowance the Department of Labor uses in its own example.[1] The late period crosses the April 1 rate change, from 7% to 6%.

PaydayLoss dateWithheldReached planDaysRatesLost earnings
Mar 13Mar 17$6,200.00May 155914 days at 7%, then 45 days at 6%$62.82
Mar 27Mar 31$6,150.00May 154545 days at 6%$45.66
Apr 10Apr 14$6,310.00May 153131 days at 6%$32.23
Total$18,660.00$140.71

Computed by the calculator above. Rates: 7% for the first quarter of 2026, 6% for the second, the IRS underpayment rates for those quarters.

Every deposit reached the plan within 180 days and the lost earnings are under $1,000, so this correction may qualify for self correction. Self correction measures from payday instead, which makes the same schedule come to $154.44 rather than $140.71. The difference is small here, but on a correction near the $1,000 limit it can decide which route you are on. The company pays the lost earnings from its own money, not from the plan.

How this compares with the Department of Labor calculator

Department of Labor Online Calculator

  • One principal amount per calculation, with its loss, recovery and final payment dates.[2]
  • The official tool. Self correctors are required to use it, and a full program application may rely on it.[1]
  • Results are saved by printing or copying them out.[2]

This calculator

  • A whole schedule at once: paste every late pay period and get each row and the total.
  • Applies the $100,000 higher-rate test across the whole correction, not row by row.
  • Flags whether the schedule fits the self correction limits, and exports the rows as CSV.
  • Same method, but not the official record. Check the final figures against the Department of Labor calculator before you file.
Sources
  1. Voluntary Fiduciary Correction Program, 90 FR 4192 (Jan. 15, 2025), section 5(b)(3) to (6), Loss Date, Recovery Date and Lost Earnings, at 4213 to 4214
  2. Department of Labor: VFCP Online Calculator
  3. IRS Revenue Procedure 95-17, interest compounding factors (cited by the program at 90 FR 4213, note 63)

Questions people ask about this

How are lost earnings on a late 401(k) deposit calculated?

Interest runs from the day the contribution should have reached the plan to the day it did, at the IRC section 6621 underpayment rate in force in each calendar quarter, compounded daily. Because the rate changes quarterly, a deposit that was late across a rate change accrues at more than one rate. This is the method the Voluntary Fiduciary Correction Program specifies, and the same one behind the Department of Labor's own calculator.

Can late deposits be self corrected without a full filing?

Since March 17, 2025 there is a self correction route for deposits made within 180 days of withholding where lost earnings come to $1,000 or less. You file an electronic notice instead of a full application. The $1,000 test applies per transaction, normally each pay period, although the Department of Labor permits grouping pay periods that are close together and share one cause.

Can we pay the lost earnings out of plan assets?

No. Section 5(c) of the program requires correction costs, lost earnings and excise taxes included, to be paid with employer money rather than from plan assets, participant accounts or forfeitures. The annual plan audit fee is a different category and can generally be paid from plan assets.

What happens if we file the 5500 and leave this open?

An uncorrected late deposit does not age out. It is reported on the Schedule H supplemental schedule for delinquent contributions every year until it is fully corrected, so a 2025 failure appears in the audited 2026 filing. Each open year is also its own prohibited transaction with a 15% excise tax and a Form 5330.

Which date do I enter as the loss date?

It depends on how you are correcting. In a full Voluntary Fiduciary Correction Program application, the loss date is the date the plan lost the use of the money: the day the withholding could reasonably have been separated from company funds, which the Department of Labor's own example puts two business days after payday. Under the self correction component, the loss date is the date of withholding itself, normally payday, so the lost earnings come out slightly higher.

Do I have to use the Department of Labor's calculator?

For self correction, yes: the 2025 program rule requires self correctors to use the Department of Labor's Online Calculator. For a full program application you may use that calculator or calculate by hand, as long as the application includes enough detail to verify the figures. A batch calculator is useful for seeing a whole schedule at once and sizing the correction, but check the final figures against the Department of Labor's tool before you file.