Last reviewed June 2026

What is Form 5500, and who has to file it?

Short answer: Form 5500 is an annual report to the U.S. Department of Labor about an ERISA benefit plan. For health and welfare plans it is generally required when the plan has 100 or more participants at the start of the plan year, or whenever the plan is funded (holds assets in a trust).

Form 5500 is an annual filing required by the Department of Labor (DOL), in coordination with the IRS and Pension Benefit Guaranty Corporation (PBGC). It is used to report information about employee benefit plans, including group health and welfare plans subject to ERISA.

Who must file:

  • Employers with 100 or more participants in an ERISA-covered health or welfare benefit plan at the beginning of the plan year

  • Employers of any size with a funded plan (i.e., holding assets in a trust, which is rare for health plans)

Types of plans that may trigger a filing:

  • Medical, dental, and vision plans

  • Health FSAs

  • Group life or disability insurance

  • Other welfare benefits like accident, hospital indemnity, or AD&D

Employers that only offer fully insured benefits without 100+ participants generally don’t have to file, but Wrap plans can consolidate multiple benefits and may change filing obligations.

Sources

Topic: Form 5500