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Department of Labor Issues Final Rules on Changes to 2023 Form 5500

Mar 2, 2023

The U.S. Department of Labor, the Internal Revenue Service, and the Pension Benefit Guaranty Corporation(“PBGC”) on February 23 released changes to the 2023 Form 5500 and Form 5500-SF. This is the third and final phase of changes that implement a September 2021 regulatory proposal, which included changes related to provisions in the SECURE Act affecting annual reporting requirements.

The Form 5500 Series is a compliance, research, and disclosure tool that contains information about a retirement plan’s financial condition, plan qualifications, operation, and compliance with government regulations

Plan sponsors must generally file 5500 forms on the last day of the seventh month after their plan year ends. The 2023 plan year reports, which will be filed beginning in mid-2024, include the following changes:

  • A consolidated Form 5500 reporting option for certain groups of defined contribution retirement plans, improved reporting by pooled employer plans and other multiple-employer plans;
  • A change in the participant-counting methodology for determining eligibility for simplified reporting alternatives available to small plans, which are generally plans with fewer than 100 participants;
  • A breakout of reporting on administrative expenses paid by the plan on the plan’s financial statements;
  • Further improvements in financial and funding reporting by PBGC-covered defined benefit plans;
  • The addition of selected Internal Revenue Code compliance questions to improve tax oversight and compliance of tax-qualified retirement plans;
  • Technical and conforming changes as part of the annual rollover of forms and instructions;
  • Technical adjustments that address certain provisions in SECURE 2.0 Act of 2022 regarding 403(b) multiple employer plans, including:
    • pooled employer plans;
    • minimum required distributions;
    • and audit requirements for plans in defined contribution group reporting arrangements.

Mock-ups of the forms and instructions will be available at

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Peter Alwardt

Peter Alwardt is a Partner and the National Tax Leader of Employee Benefit Plans, specializing in employee benefits, tax and ERISA issues for domestic and international clients. He is a member of the American Institute of Certified Public Accountants and NY State Society of CPAs.

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