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On December 15, the U.S. Department of Labor (DOL) announced updates to the annual benefits plan report/return filings. In general, the DOL’s Employee Benefits Security Administration (EBSA) teamed up with the Internal Revenue Service (IRS) and Pension Benefit Guaranty Corporation (PBGC). As part of this joint effort, the agencies released informational copies of the 2025 Form 5500, Form 5500-SF, IRS Form 5500-EZ, IRS Form 5558, and related instructions online. Subsequently, the IRS will release paper copies of Form 5500-EZ and instructions for 2025 separately on its website. This will occur after January 1st, 2026. Previously, in November 2025, the IRS unveiled updated benefit contribution limits for retirement plans effective in 2026. In summary, the agency stated that these adjustments are part of its commitment to help Americans secure their financial futures.
Overview of the Form 5500 Series Return/Report
In summary, the DOL developed the Form 5500 series annual benefits plan return/report with the IRS and the PBGC. The Form 5500 allows employee benefit plans to satisfy annual reporting requirements. Specifically, these reporting requirements fall under Title I and Title IV of ERISA and the Internal Revenue Code. Basically, ERISA sets minimum standards for most private-sector voluntary retirement and health plans. Specifically, ERISA protects individuals in these plans. The Form 5500 series return/report ensures that employee benefit plans comply with specific prescribed standards. Additionally, it ensures that participants, beneficiaries, and regulators have access to sufficient information about their rights under employee benefit plans. Form 5500 annual benefits plan report/return filings are among the five types of employee records all employers must keep.
Changes to the 2025 Form 5500 Series Return/Report
Explicitly, employers will find important modifications to the 2025 Form 5500 series return/report in the Instructions’ “Changes to Note” section. Specifically, the Changes to Note sections for Form 5500 and Form 5500-SF indicate the following changes:
- New plan characteristic codes, 1J, 1K, and 1L, added to Form 5500 for use in identifying multiemployer defined benefit plans terminated as a result of mass withdrawal, plan amendment, or insolvency.
- New plan characteristic code, 1G, added for use on both forms to identify defined benefit plans that use a variable annuity benefit formula.
- Existing plan characteristic code 1H modified on Form 5500 to clarify that it applies only to terminated single-employer PBGC-covered plans.
Employers Takeaways
In conclusion, employers should note that they cannot use Form 5500 informational copies to file their 2025 Form 5500 series annual benefits plan return/report. Filers may instead access the EFAST2 website for the official electronic versions of the Form 5500 Series as they become available for filing purposes. Additionally, employers may call the EFAST2 help desk at 866-463-3278 for further assistance or email the agency at [email protected].
