The Form 5500 serves not merely as a regulatory obligation, but as an essential instrument for promoting transparency and maintaining compliance with ERISA requirements for employer-sponsored benefit plans. Whether you're approaching the filing process for the first time or looking for a refresher, a solid understanding of Form 5500 fundamentals can distinguish you as a knowledgeable and reliable advisor to your clients.
What Is Form 5500?
Form 5500 is an annual filing mandated under the Employee Retirement Income Security Act (ERISA) for most employer-sponsored retirement and health and welfare benefit plans. It is submitted electronically via the U.S. Department of Labor’s EFAST2 system and becomes part of the public record, ensuring both regulatory oversight and plan transparency.
Who Is Required to File?
In general, plans that cover 100 or more participants at the beginning of the plan year are required to file, unless they meet the criteria for the small plan exemption applicable to certain unfunded plans. It is important to note that the participant count includes both active and former employees with vested benefits but does not extend to spouses or dependents.
Funded vs. Unfunded Plans
Unfunded plans are those financed through an employer’s general assets or insurance and may be eligible for the small plan exemption from Form 5500 filing requirements. In contrast, funded plans, which involve participant contributions or are held in trust, are generally required to file regardless of participant count, unless they qualify under specific exceptions, such as certain cafeteria plan provisions.
Wrapped vs. Unwrapped Plans
Wrapped plans consolidate multiple benefit offerings under a single ERISA plan number, enabling a unified Form 5500 filing. On the other hand, unwrapped plans must file a separate Form 5500 for each distinct line of coverage, which can significantly increase administrative complexity.
Filing Deadlines
Form 5500 filings are due seven months following the close of the plan year. Filing extensions may be obtained through:
- Form 5558, which provides a 2.5-month extension,
- Alignment with corporate tax filing deadlines, or
- Special extensions granted by the Department of Labor (DOL) or the Internal Revenue Service (IRS) in certain circumstances.
Helpful Resources:
Need support with filing or navigating plan documentation? Medcom’s team is here to help. Contact us at sales@medcombenefits.com.
