Large or small, where do you fall? Form 5500 and Audit Timelines

Insurance plan administrators are required to file IRS Form 5500, Annual Return/Report of Employee Benefit Plan. The form covers retirement plans subject to the Employee Retirement Income Security Act, or ERISA. According to the U.S. Department of Labor, ERISA “sets minimum standards for most voluntarily established pension and health plans in private industry to provide protection for individuals who have these plans.” Form 5500 must be filed no later than the last day of the seventh month following your end of the plan year. The number of participants in the plan determines the Form 5500 filings due to the IRS. According to the Department of Labor, “small” plans have less than 100 participants, while “large” plans have 100 or more participants.

Companies should be aware of the “80-120 Participant Rule” for Form 5500. Firms with between 80 and 120 plan participants at the beginning of the plan year can elect to file Form 5500-SF, Short Form Annual Return/Report of Small Employee Benefit Plan.

The number of plan participants is significant; large firms filing Form 5500 are subject to an audit from an independent qualified public accountant, while small firms filing Form 5500-SF are not.

It can be surprising to discover your plan has grown to the point that an audit is required. The audit usually leaves people wondering why and if it’s really necessary. To ensure your firm’s plan audit goes well, you need to carefully prepare, just like you would for any other IRS audit. Don’t wait until the last minute to contact your certified public accountant or search for the necessary paperwork and miss deadlines. The process is straight forward as long as you can anticipate the required audit is for a “large” audit.

Visit us at to learn more about IRS Form 5500 and how to handle audits because of it.


Internal Revenue Service, Form 5500 Corner:

U.S. Department of Labor, Employee Benefits Security Administration, EFAST2 Form 5500 and Form 5500-SF Filing Tips:

Teachers Insurance and Association of America, Filing Guidelines And Due Dates:


Dufek and Company, LLC, 80-120 Rule:

U.S. Department of Labor, Employee Benefits Security Administration, Selecting An Auditor For Your Employee Benefit Plan: