The Department of Labor (“DOL”) released informational copies online of the Form 5500 series for 2024 on November 25, 2024, along with the related instructions (see here). This includes copies of the 2024 Form 5500, Form 5500-SF, IRS Form 5500-EZ, and IRS Form 5558. The IRS will release paper copies and instructions of Form 5500-EZ separately on its website after January 1, 2025. The changes between the 2023 Form 5500 and the 2024 Form 5500 are minimal, with most changes affecting pension plans. Documented changes for the 2024 Form 5500 series are included in the instructions and listed on page one (see here). Also, beginning January 1, 2025, Form 5558 can be electronically filed through EFAST2 or filed with the IRS using a paper Form 5558.
Employer Action Items
- Begin collecting information needed for the filing and any Schedule As, if applicable, to prepare your 2024 Form 5500. Schedule A forms must be available no later than 3 ½ months after the plan year ends and due to the DOL no later than the end of the 7th month after the plan year ends unless an extension is requested.
- Review any ERISA wrap document to determine which benefits will be included in your filing and your most recent Form 5500 filing, if any.
- Become familiar with the 2024 Form 5500 and contact your vendor to confirm and schedule the preparation of your filing.
Summary
The primary reporting obligation under ERISA for welfare benefit plans is the Form 5500 annual report requirement. Unless an exemption applies, employee benefit plan administrators (commonly employers) must file an annual return reporting the financial condition, investments, and operations of each ERISA plan sponsored by a reporting employer. The Form 5500 Series is an important compliance, research, and disclosure tool for the DOL, a disclosure document for plan participants and beneficiaries, and a source of information and data for use by other federal agencies, Congress, and the private sector in assessing employee benefit, tax, and economic trends and policies. The annual reporting obligation is generally satisfied by preparing and submitting the Form 5500 Annual Return/Report of Employee Benefit Plan, including any required schedules and attachments, with the DOL.
Annually, informational copies of the current year’s Form 5500s are released. The DOL released the 2024 Form 5500 series on November 25, 2024, along with the related instructions. As indicated above, the changes between the 2023 Form 5500 and the 2024 Form 5500 are minimal, with most changes affecting pension plans. Changes can be found on page one of the instructions. Plan administrators should not use these informational copies to file their Form 5500 Series Annual Returns/Reports. Instead, filers should monitor efast.dol.gov to learn when official electronic versions are accessible and can be filed using software from EFAST2-approved vendors or directly through the EFAST2 website.
While we encourage plan administrators to file in a timely manner and without an extension, beginning January 1, 2025, Form 5558 can be electronically filed through EFAST2 or filed with the IRS using a paper Form 5558.
Additional Resources
- Form 5500 Series
- 2024 Instructions for Form 5500
- DOL News Release: Information For Annual Benefits Plan Report/Return Filings
For more information
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