Form 5500 Schedules: What Filers Need to Include

The Form 5500 series is an annual report developed by the Department of Labor (DOL), the Internal Revenue Service (IRS), and the Pension Benefit Guaranty Corporation (PBGC). Its purpose is to satisfy the yearly reporting obligations for employee benefit plans under the Employee Retirement Income Security Act (ERISA) and the Internal Revenue Code. This reporting provides a transparent view into the plan’s operations and financial condition for both federal agencies and plan participants.

Determining Your Filing Requirement

Sponsors of employee benefit plans subject to ERISA are required to file a Form 5500. These plans fall into two primary categories: pension benefit plans and welfare benefit plans. Pension plans include arrangements like 401(k)s, profit-sharing plans, and defined benefit plans, while welfare plans encompass benefits such as medical, dental, life insurance, and disability coverage. A filing requirement for many welfare plans is triggered when the plan covers 100 or more participants on the first day of the plan year.

The specific version of the form a sponsor must file depends on the plan’s size and structure. The standard Form 5500 is intended for “large” plans. For defined contribution plans, such as 401(k)s, large plans are those with 100 or more participants with an account balance at the beginning of the plan year.

For “small” plans with fewer than 100 participants, the Form 5500-SF (Short Form) may be an option. To qualify for this simplified filing, the plan must meet certain conditions, such as having all its assets invested in securities with a readily determinable fair market value. A special “80-120 rule” allows plans with between 80 and 120 participants to continue filing the same form as the previous year, potentially avoiding the more demanding requirements of the full Form 5500.

A third version, Form 5500-EZ, is available for one-participant retirement plans, which cover only a business owner or partners and their spouses. A filing requirement for Form 5500-EZ is triggered only if the plan’s assets exceed $250,000 at the close of the plan year.

Information and Schedules Needed for Form 5500

The initial part of the form requires basic identifying details, including the official plan name, the plan sponsor’s name and Employer Identification Number (EIN), and the name and address of the plan administrator. Following the identification details, filers must provide operational information. This includes entering specific plan characteristics codes that describe the features of the plan, such as whether it is a 401(k) plan or a defined benefit plan, and reporting the number of plan participants.

Schedule A is required if any plan benefits are provided through an insurance contract. This schedule reports details about the insurance products, including any commissions paid to agents or brokers.

Schedule C provides transparency on the compensation paid to plan service providers. It must be filed if any single service provider received $5,000 or more in direct or indirect compensation from the plan.

The primary financial schedules are Schedule H for large plans and Schedule I for small plans. Schedule I requires a summary of the plan’s assets, liabilities, income, and expenses, while Schedule H demands more extensive financial statements, including a balance sheet and an income statement.

Retirement plans may also need to file Schedule R, which reports information on pension funding and distributions. For large plans, an audit performed by an Independent Qualified Public Accountant (IQPA) is required. The IQPA’s report, which expresses an opinion on the fairness of the plan’s financial statements, must be attached to the Form 5500 filing.

The Form 5500 Filing Process

All Form 5500 and Form 5500-SF returns must be submitted electronically. The Department of Labor mandates the use of its ERISA Filing Acceptance System (EFAST2) for all submissions. To begin the submission process, filers must first obtain credentials, including a user ID and password, to access the EFAST2 system.

Once registered, filers have two options for submitting their completed return. They can use EFAST2-approved third-party software or use the DOL’s free IFILE web-based service to upload and file the completed forms and schedules.

The standard deadline for filing Form 5500 is the last day of the seventh month after the plan year ends. For plans that operate on a calendar year, this makes the due date July 31.

If a plan sponsor needs additional time to complete the filing, a one-time extension is available. To receive this extension, the filer must submit Form 5558, Application for Extension of Time To File Certain Employee Plan Returns, to the IRS on or before the original filing deadline. A properly filed Form 5558 grants an automatic two-and-a-half-month extension, moving the deadline to October 15 for calendar-year plans.