Joint Effort Could Signal Major Form 5500 Changes

The IRS, the Department of Labor (DOL) and the Pension Benefit Guaranty Corporation (PGBC) published proposed updates to the Form 5500 annual return in the Federal Register on July 21, 2016, that could have a significant effect on plan reporting.

Plans subject to the Employee Retirement Income Security Act of 1974 (ERISA) must file annual returns, the Form 5500 or for small filers, the Form 5500-SF along with required attachments and schedules. The IRS, the DOL and the PGBC use the information reported to enforce compliance with ERISA, but the data also provide plan participants insight into the way their retirement plan operates.

Proposed updates to the Form 5500 (Report of Employee Benefit Plan) and the Form 5500-SF (Report of Small Employee Benefit Plan) came in two parts, annual information and return reports and annual reporting and disclosure. Both sets of changes would require additional information from plan filers that would assist the agencies with their compliance monitoring and provide data the public and beneficiaries could use to understand plans and their investments. Taken together, the changes fulfill five goals:

  • Modernize financial reporting
  • Provide greater information regarding group health plans
  • Enhance data mineability
  • Improve service provider fee information
  • Enhance compliance with ERISA and the code.

The proposed changes to the Form 5500 would significantly increase reporting obligations for health and welfare plans.

All updates to the Form 5500 are also coordinated with updates to the ERISA Filing Acceptance System II (EFAST2), the electronic processing system for the Form 5500 and Form 5500-SF.

Most of the changes take effect for the Plan Year 2019 Form 5500. Comments on the changes are due to the DOL before October 4, 2016.

Stay tuned for more information about how the various proposed changes could affect your reporting. For specific comments, questions or concerns about the changes, please contact Hal Hunt of MHM’s Professional Standards Group. Hal can be reached at or 816.945.5610.

Published on September 27, 2016