Form 5500 schedules, and which ones your plan attaches

The Form 5500 that an ERISA plan files with the Department of Labor is a main form plus schedules, and which schedules attach depends on the plan's type and whether it files as a small or large plan. The table below follows section 4 of the 2025 instructions.

This page is about the ERISA Form 5500, the annual return/report that employee benefit plans file with the Department of Labor and the IRS through EFAST2. The same number is used for an unrelated US Navy supply form, and other countries use different form numbers for their pension returns; none of that applies here.

The schedules do not change the due date. For any plan year end, the clock gives the date and whether a return is late.

Run the Form 5500 Rescue Clock

Every schedule in one table

This is the instructions' What To File section turned into one table. "Large" and "small" mean the plan's filing category, counted the way the small or large plan page explains. A small plan filing Form 5500-SF instead of Form 5500 follows that form's own instructions.

Form 5500 schedules, what each covers and who attaches it
ScheduleWhat it coversWho attaches it
ABenefits or investments provided through an insurance company or similar organizationAny plan with such a contract, small or large. Not for administrative services only contracts
CService providers and what they were paidLarge plans, MTIAs, 103-12 IEs, DCGs and GIAs, when the pay or termination test is met
DInvestments in pooled entities that file as DFEsPart I: any plan or DFE invested in an MTIA, 103-12 IE, CCT or PSA. Part II: DFE filings except DCGs
GLoans and leases in default or uncollectible, and nonexempt transactionsLarge plans, MTIAs, 103-12 IEs, DCGs and GIAs that answer yes on Schedule H lines 4b, 4c or 4d
HFull financial statementsLarge pension and welfare plans, and all DFE filings
IShort financial statementsSmall pension and welfare plans that file Form 5500 rather than Form 5500-SF
MBActuarial informationMost multiemployer defined benefit plans, and money purchase plans amortizing a funding waiver
SBActuarial informationMost single-employer defined benefit plans, including multiple-employer defined benefit plans
RRetirement plan informationDefined benefit plans and other plans subject to Code section 412 or ERISA section 302, and certain other pension plans
MEPMultiple-employer plan informationMultiple-employer pension plans
DCGEach plan's own information inside a DCGEvery plan participating in a DCG, each on its own schedule

Schedule A: insurance

Under the 2025 Instructions for Form 5500, Section 4: What To File, pages 8 and 9, Schedule A is required if any benefits under the plan are provided by an insurance company or similar organization, including investment contracts with insurance companies, and is not filed for administrative services only contracts.

A fully insured health plan that files carries a Schedule A for each contract. So does a 401(k) holding a group annuity contract with an insurer. A self-funded plan that pays an insurer only to administer claims does not.

Schedule C: service providers

Under the 2025 Instructions for Form 5500, Section 4: What To File, pages 8 and 9, a large plan, MTIA, 103-12 IE, DCG or GIA files Schedule C if any service provider received $5,000 or more in compensation, directly or indirectly, from the plan or DFE during the year, or if an accountant or enrolled actuary was terminated.

Indirect pay counts toward the $5,000, which is why recordkeepers and advisers paid through fund revenue sharing show up here. Small plans do not file Schedule C at all.

Schedules H and I: the financial statements

Under the 2025 Instructions for Form 5500, Section 4: What To File, pages 8 and 9, Schedule H is required for pension and welfare plans filing as large plans and for all DFE filings.

Under 29 CFR 2520.103-1(b)(5), the annual report of a plan with 100 or more participants normally includes a report from an independent qualified public accountant.

A small plan filing Form 5500 uses the shorter Schedule I instead, and a small plan that qualifies for Form 5500-SF reports its financial lines on that form with no Schedule I. The choice between H and I follows the same count that decides small or large, so a plan that crosses 100 can change schedule and pick up the audit in the same year.

Schedules SB, MB and R: defined benefit plans

A single-employer defined benefit plan attaches Schedule SB, with the enrolled actuary's figures. A multiemployer defined benefit plan attaches Schedule MB. Under the same section, Schedule R is required for a defined benefit plan and any other pension plan subject to Code section 412 or ERISA section 302, and may be required for certain other pension plans. A 401(k) plan usually needs none of the three, though the instructions list cases where Schedule R applies to other pension plans.

What is not a schedule

Form 8955-SSA, which reports separated participants with vested benefits, used to be Schedule SSA. It is now a separate IRS form and does not go through EFAST2. The Form 8955-SSA page covers it. For what the main form is and who reads it, see what is Form 5500.

Questions

Who has to file Schedule C?

A large plan, MTIA, 103-12 IE, DCG or GIA, if any service provider received $5,000 or more in compensation, directly or indirectly, from the plan or DFE during the year, or if an accountant or enrolled actuary was terminated. Small plans do not file it.

Does a small plan file Schedule H?

No. A small plan that files Form 5500 attaches Schedule I. Schedule H is for plans filing as large plans and for DFE filings. A small plan eligible for Form 5500-SF files that form instead.

Is Schedule A needed for an administrative services only contract?

No. Schedule A covers benefits provided by an insurance company or similar organization, including investment contracts with insurers. The instructions say not to file it for administrative services only contracts.

Which plans file Schedule R?

Defined benefit plans and other pension plans subject to Code section 412 or ERISA section 302. The instructions add that certain other pension plans may need it too.

Sources

  1. Department of Labor, Form 5500 series forms and instructions: https://www.dol.gov/agencies/ebsa/employers-and-advisers/plan-administration-and-compliance/reporting-and-filing/form-5500
  2. EFAST2, filing and public search: https://www.efast.dol.gov/

Figures on this page were last verified against these sources on 2 November 2026. Where this page and the Department of Labor or the IRS disagree, the agency is right and this page is wrong; tell us at hello@02launch.com.

Who made this

02Launch is an AI engineering firm out of Google and Microsoft. We built the Form 5500 Rescue Clock because the late Form 5500 decision sits across two agencies and nobody had put it in one place for a plan book.

Schedule C and the move to Schedule H catch plans out. A call with our engineers is about seeing it coming:

Speak with our team

More on Form 5500