The 1019 Tax Form: What Is It Actually For?
Understand the true function of Form 1019. This guide clarifies its role as a DOL application for employee benefit plan IDs, not an IRS tax document.
Many people searching for information on employee benefit plans assume they are all issued by the Internal Revenue Service (IRS). However, when it comes to establishing a unique identity for a benefit plan, the process is managed by the U.S. Department of Labor (DOL). A search for “Form 1019” for this purpose will be fruitless, as no such form exists for obtaining a plan identification number.
The unique identifier for an employee benefit plan is not obtained by filing a standalone application. Instead, a plan receives its official identifying number when the plan sponsor files its first Form 5500, Annual Return/Report of Employee Benefit Plan. This report is a requirement of the Employee Retirement Income Security Act of 1974 (ERISA), a federal law that sets minimum standards for most voluntarily established retirement and health plans in private industry. The filing itself establishes the plan’s existence with the DOL and assigns its unique number.
Who Needs a Plan Number
Any organization that sponsors an employee benefit plan subject to ERISA is required to obtain a plan number. This includes businesses of all sizes that offer benefits such as medical, dental, or vision plans, as well as retirement plans like 401(k)s or pension plans. The entity responsible for this is the “plan sponsor,” which is the employer.
These requirements are triggered when a plan is established. For example, if a company decides to offer a group health plan to its employees, that plan falls under ERISA regulations. Consequently, the company, as the plan sponsor, must ensure the plan is properly identified for reporting purposes. This identification is what necessitates filing a Form 5500 and, in doing so, formally establishing the plan’s unique number with the Department of Labor.
Information for Your First Form 5500
When preparing to file Form 5500 for the first time, the plan sponsor must gather specific information. The form requires the plan sponsor’s legal name, mailing address, and nine-digit Employer Identification Number (EIN). This EIN, assigned by the IRS, serves as the foundation for the plan’s full identifier.
The plan sponsor must also assign the plan a three-digit number. According to DOL rules, welfare benefit plans (like health or dental plans) should be numbered sequentially starting with 501. If an employer establishes a health plan, it would be assigned plan number 501. If that same employer later adds a separate dental plan, it would be assigned 502. This self-assigned number, once filed, becomes permanent for the life of that plan and cannot be used for another plan even if the original is terminated.
The combination of the sponsor’s nine-digit EIN and this new three-digit plan number creates the unique 12-digit identifier used by the DOL and IRS. For instance, if a company with EIN 12-3456789 establishes its first welfare plan, the full plan number reported on Form 5500 would be 123456789501. This complete number must be used on all subsequent filings and included in the Summary Plan Description (SPD) provided to employees.
The Filing Process
Once the necessary information is gathered and the three-digit plan number is assigned, the Form 5500 must be filed electronically. Paper filings are not accepted. The submission is made through the DOL’s EFAST2 (ERISA Filing Acceptance System). The plan sponsor or administrator will need to obtain credentials to log in to the system and either complete the form online or upload a file prepared with approved software.
Upon the successful electronic submission of the initial Form 5500, the plan is officially registered with the Department of Labor. There is no separate confirmation letter that issues the number; the acceptance of the filing itself solidifies the plan’s identity.