Short answer: No. HSAs are individually owned and QSEHRAs are exempt from ERISA by statute, so neither requires a Form 5500 on its own. But other ERISA-covered benefits offered alongside them may still require a filing if the participant threshold is met.
Employers that only offer Health Savings Accounts (HSAs) or Qualified Small Employer HRAs (QSEHRAs) do not need to file Form 5500, because these arrangements are not considered ERISA-covered welfare plans.
HSAs:
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HSAs are individual-owned accounts, not group health plans.
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As long as the employer limits its role to contributions and payroll deductions, the HSA is not subject to ERISA.
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HSAs offered alongside a high-deductible health plan (HDHP) may be mentioned in SPD materials, but the HSA itself doesn’t require a 5500.
QSEHRAs:
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QSEHRAs are exempt from ERISA by law, so no Form 5500 is required.
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Employers must meet eligibility rules and provide required QSEHRA notices, but no SPD or 5500 filing applies.
However, if an HSA or QSEHRA is offered alongside other ERISA-covered benefits, those other plans may still require a 5500 filing if the employer meets the participant threshold.
Sources
- U.S. Department of Labor / EBSA, Form 5500 (reporting and filing): dol.gov Form 5500
- DOL Field Assistance Bulletins 2004-01 & 2006-02 (HSAs and ERISA); 21st Century Cures Act / IRC §9831(d) (QSEHRA ERISA exemption).
Content history
Originally published: June 16, 2025
Last reviewed: June 16, 2026