Form 5500 Annual Reporting Requirements for Employee Benefit Plans and DFEs
Overview of Form 5500 Annual Reporting Requirements
The Form 5500 filing requirements vary
according to the type of filer. Certain employee benefit plans may be
exempt from the annual reporting requirements or eligible for limited
reporting options. The major classes of plans exempt from filing an
annual report or eligible for limited reporting are described in the Form 5500 instructions.
A welfare benefit plan (including a
group health plan) that covered fewer than 100 participants as of the
beginning of the plan year and is unfunded, fully insured, or a
combination of insured and unfunded, is generally not required to file
Form 5500. The following describes in more detail the categories of
welfare benefit plans with fewer than 100 participants that may qualify
for this exemption:
- An unfunded welfare benefit plan has its benefits paid as needed directly from the general assets of the employer that sponsors the plan.
- A fully insured welfare benefit plan has its benefits
provided exclusively through insurance contracts or policies, the
premiums of which must be paid directly to the carrier by the employer
from its general assets or partly from its general assets and partly
from employee contributions.
- A combination unfunded/insured welfare benefit plan has its
benefits provided partially as an unfunded plan and partially as a fully
insured plan, such as a plan that provides medical benefits as
described in the first bullet above and life insurance benefits as in
the second bullet.
Form 5500 Filers by Category
For employee benefit plans that are not exempt from the Form 5500 annual reporting requirements, there are three general types of filers:
- Small plans (generally plans with fewer than 100 participants as of the beginning of the plan year);
- Large plans (generally plans with 100 or more participants as of the beginning of the plan year); and
- DFEs—direct filing entities..