DOL Releases Information Copies of 2023 Form 5500 Annual Series

On November 17, 2023, the DOL, IRS and Pension Benefit Guaranty Corporation released the 2023 Form 5500 series, including Form 5500, Form 5500-SF, Form 5500-EZ, Schedules, and Instructions.

The key revisions for 2023 reflect changes made by the SECURE Act as described in a previous agency action (see our March 2, 2023, Compliance Corner article ). A few of the changes, most of which relate to defined benefits plans, were previously implemented in 2022 (see our June 9, 2022, Compliance Corner article ).

The most significant changes include:

• A new filing option for a defined contribution group (DCG), called a DCG reporting arrangement, and a new Schedule DCG (Individual Plan Information) to report individual plan information. Large plans in a DCG and small plans that do not meet audit waiver conditions are subject to separate plan-level audits.
• A new Schedule MEP (Multiple-Employer Pension Plan Information) to report information specific to MEPs, including participating employer and aggregate account information.
• Changes to how defined contribution retirement plan participants are counted by basing the count on the number of participants with account balances rather than the current method that counts individuals who are eligible to participate even if they have not elected to participate and do not have an account in the plan.
• Amendments to Schedules H, R, and SB to improve financial transparency and reporting, including the new subcategories for administrative expenses in Part II of Schedule H.
• The addition of certain Code compliance questions to improve tax oversight and compliance of tax-qualified retirement plans.

The instructions have also been updated to reflect the current maximum DOL administrative penalty for Form 5500 filing failures of $2,586 per day.

2023 Form 5500 Series »
News Release »
Fact Sheet (Released February 23, 2023) »