Agencies Propose Revisions to Form 5500

The Employee Benefits Security Administration, Internal Revenue Service, and Pension Benefit Guaranty Corporation have proposed revisions to the Form 5500. The Form 5500 is an annual filing required of private-sector employee benefit plans.

Many of the proposed changes to the form are in response to the SECURE Act. The proposed changes include a new schedule for defined contribution retirement plans, which would allow the Departments of Labor and Treasury to develop a consolidated annual report for groups of defined contribution plans as required by the Act. The new form would also address pooled employer plans as a new type of retirement plan. It would also move the questions regarding participating employers in multiple employer welfare plans that provide medical benefits (which are currently part of the Form 5500) to a new form. The changes would further improve financial reporting for retirement plans in general, including by adding new fee and expense reporting requirements and enhancing the format and content of the existing schedules of assets held for investment. The updated form would also have additional questions to improve financial and funding reporting by PBGC-covered defined benefit pension plans.

If adopted, the updated Form 5500 would generally be effective for plan years beginning on or after January 1, 2022, which are usually filed beginning in July 2023.