Is this the right page? This page covers Form 5500 for health and welfare benefit plans: medical, dental, vision, life, disability, FSA, and similar group benefits. For retirement plans (401(k), pension), see the Form 5500 (Retirement Plans) page.
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What
Annual ERISA return/report (Form 5500 or 5500-SF) for welfare benefit plans: medical, dental, vision, life, disability, FSA, and similar group benefits, filed electronically via EFAST2.
Who
Welfare plans with 100 or more participants at the start of the plan year. Also any welfare plan that holds assets in trust (funded) or is a multiple-employer welfare arrangement (MEWA), regardless of size. Small (under 100) unfunded, fully insured, single-employer welfare plans are generally exempt.
When
Due the last day of the 7th month after the plan year ends: July 31 for calendar-year plans. A 2.5-month extension is available by filing Form 5558 with the IRS by the original due date.
Risk
DOL penalties up to $2,739 per day (2026, adjusted annually) with no maximum cap; IRS penalties up to $250 per day (max $150,000 per return). The DOL's Delinquent Filer Voluntary Compliance Program (DFVCP) offers substantially reduced penalties for late filers who come forward voluntarily.
100+
Participant threshold
Large welfare plans (and all funded plans/MEWAs regardless of size) must file.
Jul 31
Calendar-year due date
The last day of the 7th month after plan year end.
2.5 mo
Extension (Form 5558)
File Form 5558 with the IRS by the original due date to extend to October 15.
| Item | Calendar-Year Plan | Notes |
|---|---|---|
| Form 5500 due | July 31, 2025 (for 2024 plan year) and July 31, 2026 (for 2025 plan year) | Due last day of the 7th month after plan year end. |
| Form 5558 extension | File by July 31 to extend to Oct 15, 2025 / Oct 15, 2026 | 2.5-month extension; file separately with IRS (not EFAST2). |
| Request Schedule A from carriers | Request in early spring (March to April) | Carriers have until August 2 to provide Schedule A, but requesting early avoids last-minute delays. You need one per insurer per contract. |
Item: Form 5500 due
When: July 31 (calendar-year plans)
Notes: Last day of the 7th month after plan year end.
Item: Form 5558 extension
When: File by July 31 to extend to Oct 15
Notes: 2.5-month extension; file separately with the IRS, not EFAST2.
Item: Request Schedule A from carriers
When: Early spring (March to April)
Notes: One per insurer per contract; carriers can be slow, so request early.
- Plan information: Plan name, employer EIN, plan number, plan year, type(s) of benefits offered, and funding/benefit arrangement (fully insured, self-funded, or combination).
- Participant count: Number of participants at the start and end of the plan year. See FAQs for how to count correctly.
- Schedule A, one per insurer: Insurance information form provided by each carrier for each contract (medical, dental, vision, life, disability, etc.). Covers premiums paid and agent/broker commissions. Do not prepare this yourself; it must come from the carrier.
- Schedule C (if required): Service provider information for large plans (100+) if any service provider received $5,000 or more in direct or indirect compensation. Typically applies to brokers, TPAs, and benefit administrators.
- Wrap SPD and plan documents: You will reference these for plan type, coverage, and benefit arrangement details. See the ERISA Wrap page.
- Prior year's Form 5500: Useful for reference and for confirming plan number, EIN, and prior participant counts.
1
Confirm you must fileCheck participant count at the plan year start and whether any benefit is funded or held in trust. Small (under 100) unfunded, fully insured, single-employer plans are generally exempt.
2
Choose the right formStandard Form 5500 for large welfare plans (100+). Eligible small plans (under 100) that are required to file may use Form 5500-SF. See the schedule guide in the green section below.
3
Register in EFAST2Set up Filing Author and Filing Signer accounts if you don't already have them at efast.dol.gov.
4
Request Schedule A from each carrierContact every insurance company that provided coverage during the plan year. Allow several weeks; carriers are obligated to provide it but can be slow.
5
Complete the filingEnter plan information, participant counts, and attach all required schedules. Run EFAST2 validations and correct any errors before submitting.
6
Submit electronicallyFile through EFAST2 and save the acknowledgment (ACK) receipt as your proof of timely filing.
7
Need more time?File Form 5558 with the IRS by the original due date to get a 2.5-month extension.
- EFAST2 filing copy and ACK receiptConfirming timely submission.
- All Schedule A forms receivedFrom each carrier, for each plan year filed.
- Schedule C and other attachmentsFiled with the return.
- Participant count documentationThe census or HR records used to determine the count at plan year start and end.
- Form 5558 and proof of IRS receiptIf an extension was requested.
Common traps
Missing Schedule A from one carrier: If you have multiple insurance contracts (medical, dental, vision, life), you need a Schedule A from every carrier. Missing even one makes the filing incomplete. Request them all in early spring.
Assuming small means exempt: The small-plan exemption requires the plan to be under 100 participants AND unfunded AND fully insured by an insurance company. A funded plan (assets in trust) or MEWA must file regardless of size.
Miscounting participants: Count everyone covered at the start of the plan year: active employees, retirees receiving benefits, and COBRA continuees. Dependents do not count separately; only the employee (or primary covered individual) is the participant.
Missing the threshold crossing: Once a plan reaches 100 or more participants at the start of a plan year, it becomes a large plan and must file. The 80-120 rule (see Special Cases) gives some flexibility at the margins.
Waiting too long to request Schedule A: Carriers may take weeks to provide it. Waiting until June for a July 31 deadline leaves no room for delays. Request in March or April.
FAQs
Do HRAs and POPs have to file?
Generally only if they meet filing criteria. Small unfunded single-employer HRAs and POPs under 100 participants are typically exempt. Once you cross 100 participants, or if assets are held in trust, a filing is required.
What counts as a participant for a welfare plan?
Anyone covered under the plan at the start of the plan year: active employees enrolled in coverage, retirees receiving welfare benefits, and COBRA continuees. Dependents do not count as separate participants.
Do we file one Form 5500 or one per benefit?
It depends on how your plan is structured. Many employers wrap all welfare benefits into a single ERISA plan and file one Form 5500. If your benefits are maintained as separate plans, each plan files separately. Check your plan documents or ERISA wrap to confirm.
Who signs the Form 5500?
An authorized plan representative, typically the plan administrator, often the employer, signs electronically in EFAST2. The signing individual must have a Filing Signer account.
Can we file an amended return?
Yes. File an amended Form 5500 through EFAST2 and check the amended return box. If the amendment is also correcting a late filing, use the DFVCP to reduce penalties.
- Form 5500 & Instructions (DOL/EBSA): Complete instructions for Form 5500 and 5500-SF, including which plans must file, which schedules are required, and common filing errors.
- EFAST2 Filing Portal: The official system for submitting Form 5500 filings electronically. Includes user guides, FAQs, and account registration.
- Form 5558: Extension of Time to File (IRS): Request an automatic 2.5-month extension. Must be filed with the IRS by the original due date.
- Delinquent Filer Voluntary Compliance Program (DFVCP): The DOL's reduced-penalty program for late filers who come forward before DOL discovers the delinquency.
- Small plan exemption (under 100 participants): Plans with fewer than 100 participants that are both unfunded and fully insured through an insurance company are generally exempt from filing. If even one benefit is self-funded or assets are held in a trust, the exemption may not apply.
- 80-120 rule: If your prior year count was between 80 and 120 and you filed as a small plan, you may continue filing as small until your count clearly exceeds 120. This prevents back-and-forth between large and small status as your headcount fluctuates near the threshold.
- Funded welfare plans (trust-held assets): Any welfare plan that holds assets in a trust, regardless of participant count, must file. Many self-funded health plans are structured this way.
- MEWAs (Multiple Employer Welfare Arrangements): MEWAs must file Form 5500 regardless of participant count and may also have separate DOL registration requirements under Form M-1. Rules are complex; consult counsel.
- Plans with mixed funding: If part of your plan is fully insured and part is self-funded (e.g., insured medical plus self-funded dental), the self-funded portion may affect exemption eligibility for the entire plan. Review carefully.
- Governmental and church plans: Generally exempt from ERISA and Form 5500 filing requirements.
Use these tables to confirm which form to file and which schedules to attach. For most fully insured welfare plans, Schedule A from each carrier is the main requirement beyond the base form itself.
Which Form?
| Form | Who Uses It | Notes |
|---|---|---|
| Form 5500 | Large welfare plans (100+ participants at plan year start); all funded welfare plans regardless of size | Standard form. Required for this page's audience. |
| Form 5500-SF | Eligible small welfare plans (under 100 participants) that are required to file but not exempt | Simplified short form for small plans that don't qualify for the full small-plan exemption. |
Which Schedules? (Welfare Plans)
| Schedule | What It Covers | When Required |
|---|---|---|
| Schedule A | Insurance information: premiums paid and agent/broker commissions | Required for every insurance contract. Must come from the carrier, not prepared by the employer. One per insurer per contract. |
| Schedule C | Service provider compensation: fees paid to brokers, TPAs, and benefit administrators | Required for large plans (100+) if any service provider received $5,000 or more in direct or indirect compensation. |
| Schedule H or I | Financial information: plan assets, liabilities, and income | Required for funded welfare plans only (assets held in trust). Not applicable to unfunded or fully insured plans. |
| Schedule G | Financial transactions: loans, leases, or transactions in default | Required for funded plans with certain financial transactions. Uncommon for standard fully insured plans. |