The SAR Distribution Requirement: What You Must Send Participants by September 30

The Form 5500 Is Filed. Most Employers Stop There.

Your Form 5500 hits the DOL by July 31. Box checked. Done.

Except it's not. If your plan filed an annual report, you owe participants a Summary Annual Report. The SAR. And you've got a deadline to get it out that most HR teams don't have on the calendar.

Missing it creates an avoidable ERISA disclosure violation. The fix costs almost nothing. Here's what to know before summer ends.

The Actual Deadlines

Two deadlines matter here, and they're tied to your plan year end, not the calendar.

Form 5500 is due by the last day of the seventh month after the plan year ends. For a calendar year plan (January 1 through December 31), that's July 31.

The SAR is due nine months after plan year end. Calendar year plan? September 30. June 30 plan year end? March 31.

Here's the formula for any plan year:

• Form 5500: last day of the 7th month after plan year end.
• SAR to participants: 9 months after plan year end, or 2 months after the Form 5500 filing due date (including any approved extension), whichever is later.

If you extended your Form 5500 filing, the SAR deadline shifts. It moves to two months after the extended due date. Calendar year plan extended to October 15? SAR is due December 15.

For the 2025 calendar year specifically: SAR due September 30, 2026, unless you filed an extension.

Who Has to Send One

Simple rule: if your plan files a Form 5500, you generally owe a SAR. If the plan is exempt from filing, you generally don't.

Large welfare plans, 100 or more participants, file regardless of funding type. Fully insured, self-insured, unfunded. If the 5500 goes in, the SAR goes out.

Small plans that qualify for the filing exemption skip both. But if you're not sure your plan qualifies, confirm with your 5500 preparer or ERISA counsel. Don't assume.

What Goes in It

The SAR is short. It summarizes what's already on the 5500. You're not building a new filing.

The DOL prescribes the content (see 29 CFR § 2520.104b-10(d) for the format). Depending on how the plan is funded, it includes some combination of:

• Whether benefits are provided on an uninsured basis, through insurance, or both.
• Insurance carrier name and total premiums paid, if applicable.
• Basic financial data, if plan assets are held in a trust or separate fund.
• A notice telling participants they can request the full annual report from the plan administrator.

One thing that trips people up: "funded" versus "unfunded" isn't about employee contributions. It's about whether claims are paid from a separately maintained fund or trust, or straight from the employer's general assets. A self-insured plan paying claims out of operating cash is typically unfunded for this purpose.

You can combine the SAR with other required notices in one mailing. Just make sure the combined package satisfies the delivery rules for each notice.

Why This Lands on the CFO

The SAR is the plan administrator's obligation. That's usually the employer. Not your TPA. Not your broker.

Your vendor may draft it. Your broker may remind you. Your 5500 preparer may hand you a template. None of that shifts the legal responsibility off the plan administrator.

If you don't know whether your plan filed a 5500 this year, find out now. That answer tells you whether your SAR deadline matters.