Administration November 25, 2024

DOL Releases 2024 Form 5500 Informational Updates

They include revisions to codes for pension-linked emergency savings accounts and instructions for benefits payable in annuity form.

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The Department of Labor, IRS and Pension Benefit Guaranty Corporation on Monday released informational copies of the Form 5500 series for 2024.

The instructions on filing highlight changes made for 2024 for Forms 5500 and 5500-SF, the short-form series for small pension and welfare benefit plans. The IRS is set to release paper copies of and online instructions for Form 5500-EZ, which is for one-participant (owner/partner) plans and foreign plans, after January 1, 2025.

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The informational copies are not for filing the annual forms, the agencies noted; plan administrators should monitor efast.dol.gov to know when official electronic versions are available for filing, either with approved vendor software or the EFAST2 website.

The informational sections released Monday include “Changes to Note” for plan administrators, which included those for both Form 5500 and Form 5500-SF:

  • A new plan characteristics code, 2Y, for pension-linked emergency savings accounts created by the SECURE 2.0 Act of 2022; and
  • Updates that reflect an increase in the maximum civil penalty amount assessable under the Employee Retirement Income Security Act’s Section 502(c)(2)—for those who fail to file required reports of information—as required by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015.

Changes implemented for only Form 5500:

  • Defined contribution group plan arrangements may, without needing to attach a list of participant plans, file for an extension of time to file Form 5500; and
  • Modifications to the process of filing an attached Schedule SB reporting expected benefit payment projections when plans are reporting on benefits to be paid in the form of an annuity.

The agencies also noted that, starting on January 1, 2025, an extension request can be made via Form 5558 either electronically through EFAST2 or filed with the IRS using a paper form.

Form 5500s are submitted to the DOL, IRS and PBGC for employee benefit plans to meet filing obligations as stipulated by ERISA and the Internal Revenue Code. The forms are used by the agencies for compliance, enforcement and research.

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