As mid-year approaches, employers sponsoring benefit plans should begin preparing for upcoming Form 5500 filing obligations. For many calendar-year plans, Form 5500 filings are due by July 31, making June an ideal time to confirm whether filing requirements apply and ensure needed information is being gathered.
Form 5500 is an annual reporting requirement under ERISA that provides the Department of Labor and IRS with information about employee benefit plans, including plan structure, funding, and operations.
Which Plans May Require a Form 5500 Filing?
Form 5500 filing requirements commonly apply to certain employer-sponsored welfare benefit plans, including medical, dental, vision, life, disability, health reimbursement arrangements (HRAs), and certain other benefit programs.
In general, welfare plans with 100 or more participants at the beginning of the plan year should review whether a filing is required. However, filing obligations can vary depending on factors such as:
- Whether the plan is fully insured or self-funded
- Whether benefits are combined under a wrap document
- Whether the plan qualifies for an exemption under ERISA rules
In some cases, filing obligations may apply even below the 100-participant threshold, depending on how the plan is funded or structured.
Because filing rules can be affected by plan structure, employers should avoid assuming that filing requirements are determined solely by employer size.
Why Mid-Year Review Matters
Preparing for Form 5500 filings often requires coordination among multiple parties, including carriers, TPAs, payroll teams, accountants, and third-party administrators.
Waiting until July to review filing obligations can create challenges if plan documents are outdated, participant counts are unclear, or vendor information has not been gathered.
Mid-year review also gives employers an opportunity to confirm that:
- Plan documents and wrap documents are current
- Benefit offerings are being administered consistently with written terms
- Required schedules or attachments will be available in time for filing
- Vendor responsibilities are clearly understood
Common Areas of Confusion
One of the most common misunderstandings involves participant counts. Form 5500 filing thresholds are generally based on the number of plan participants at the beginning of the plan year, not simply the number of active employees enrolled in coverage.
Employers are also sometimes surprised to learn that multiple benefit offerings may need to be considered together when benefits are combined under a single wrap plan document.
Final Reminder
Form 5500 filings are a routine but important part of employee benefits compliance. Taking time now to review filing obligations, confirm participant counts, and coordinate with vendors can help employers avoid unnecessary delays or corrections later in the filing season.
Employers that need additional time may request an extension of the filing deadline.
If you have questions about Form 5500 filing obligations or whether your benefit plans may require filing, your INSURICA team is available to help.
This is not intended to be exhaustive nor should any discussion or opinions be construed as legal advice. Readers should contact legal counsel or an insurance professional for appropriate advice.
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