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.
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.
| Schedule | What it covers | Who attaches it |
|---|---|---|
| A | Benefits or investments provided through an insurance company or similar organization | Any plan with such a contract, small or large. Not for administrative services only contracts |
| C | Service providers and what they were paid | Large plans, MTIAs, 103-12 IEs, DCGs and GIAs, when the pay or termination test is met |
| D | Investments in pooled entities that file as DFEs | Part I: any plan or DFE invested in an MTIA, 103-12 IE, CCT or PSA. Part II: DFE filings except DCGs |
| G | Loans and leases in default or uncollectible, and nonexempt transactions | Large plans, MTIAs, 103-12 IEs, DCGs and GIAs that answer yes on Schedule H lines 4b, 4c or 4d |
| H | Full financial statements | Large pension and welfare plans, and all DFE filings |
| I | Short financial statements | Small pension and welfare plans that file Form 5500 rather than Form 5500-SF |
| MB | Actuarial information | Most multiemployer defined benefit plans, and money purchase plans amortizing a funding waiver |
| SB | Actuarial information | Most single-employer defined benefit plans, including multiple-employer defined benefit plans |
| R | Retirement plan information | Defined benefit plans and other plans subject to Code section 412 or ERISA section 302, and certain other pension plans |
| MEP | Multiple-employer plan information | Multiple-employer pension plans |
| DCG | Each plan's own information inside a DCG | Every plan participating in a DCG, each on its own schedule |
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.
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.
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.
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.
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.
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.
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.
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.
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.
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.
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: