Form 5500 Annual Report (Welfare Plans)
ERISA § 104; 29 CFR § 2520.104a-5
Annual report filed with the DOL for welfare benefit plans. Plan sponsors should ensure Schedule A from the carrier (typically obtained by the broker) is provided to whoever assembles the 5500. If you're not sure who handles this, check with your broker.
Current Fee / Rate Information
No filing fee. Plans with 100+ participants generally must include an audit by an independent qualified public accountant (IQPA). Small plans (under 100 participants) are typically exempt from audit and may qualify for simplified reporting.
Last reviewed: July 2026
Non-Compliance Penalties
DOL: Up to $250/day, max $150,000 per filing. IRS: $250/day, max $150,000. Voluntary correction via DFVCP (DOL) may reduce penalties. Extensions available via Form 5558 (2.5 additional months).
Does your welfare plan need to file?
The general rule: ERISA welfare plans with 100 or more participants at the start of the plan year file a Form 5500. Smaller plans that are fully insured or unfunded (benefits paid from general assets) are typically exempt. Count participants, not employees. A plan can cross 100 without anyone noticing.
Deadlines that matter
- Calendar-year plans: July 31.
- Need more time? Form 5558 buys 2.5 months, to October 15. File it before July 31.
- Filed late with no extension? The DFVCP program caps the damage at a fraction of the statutory penalties. Use it before the DOL writes first.
The wrap plan shortcut
Without a wrap document, each welfare benefit can be its own ERISA plan with its own 5500. A wrap plan bundles medical, dental, vision, and life into one plan and one filing. If you're filing multiple 5500s, or unsure how many plans you technically sponsor, that's the fix.
One more assembly detail: the Schedule A data comes from your carriers, usually through your broker. Request it right after the plan year closes so your preparer isn't chasing it in July.
Official Source
https://www.dol.gov/agencies/ebsa/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500Related Reading
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