DOL Releases Advance Copies of 2024 Form 5500 and Form 5500-SF

Published November 26, 2024

The U.S. Department of Labor (DOL), the Internal Revenue Service (IRS), and the Pension Benefit Guaranty Corporation (PBGC) released advance informational copies of the 2024 Form 5500 Annual Return/Report and related instructions, and Form 5500-SF and instructions.

Pension and welfare benefit plans required to file an annual return/report regarding their financial conditions, investments and operations generally satisfy that requirement by filing the appropriate Form 5500 form, including any required schedules and attachments, under the all-electronic EFAST2 system.

The "Changes to Note" section of the 2024 instructions for each of the forms highlights important modifications to the forms, schedules and instructions. 

Changes are summarized below:
  • Plan Characteristics Code for Pension-Linked Savings Accounts:
    • Section 127 of the SECURE 2.0 Act of 2022 added ERISA section 801 which provides for pension-linked emergency savings accounts. Filers with respect to plans that have a pension-linked emergency savings account must use the new plan characteristic code, 2Y, which has been added to the List of Plan Characteristics Codes to identify this feature on the Form 5500 (line 8a) and Schedule DCG (line 8).
  • Form 5558 for a DCG Reporting Arrangement:
    • The plan administrator of the DCG reporting arrangement can file a single Form 5558 for an extension of time to file a Form 5500 Annual Return/Report and is not required to attach a list of participating plans in the DCG to the Form 5558.
  • Schedule SB:
    • The instructions for the Schedule SB, line 26b expected benefit payment projection attachment are modified for situations when a plan is subject to the annuity substitution rule (26 CFR 1.430(d)1(f)(4)(iii)(B)) to determine the funding target. The instructions now provide that such plans report expected benefits payable in an annuity form.
  • Administrative Penalties:
    • The instructions have been updated to reflect an increase in the maximum civil penalty amount assessable under ERISA section 502(c)(2), as required by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015.
Advance copies of the 2024 Form 5500 series are for informational purposes only and cannot be used to file a 2024 Form 5500 series Annual Return/Report.