DOL Releases Advance Copies of 2022 Form 5500 and Form 5500-SF

Published December 09, 2022

The Employee Benefits Security Administration (EBSA), the Internal Revenue Service (IRS) and the Pension Benefit Guaranty Corporation (PBGC) released advance informational copies of the 2022 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 2022 instructions for each of the forms highlights important modifications to the forms, schedules and instructions. Changes are summarized below:

  • Multiple-Employer Pension Plans: 
    • New plan characteristics codes have been added for Form 5500, Part II, line 8a, to identify different types of multiple employer defined contribution plans filing the Form 5500 (pooled employer plans, association retirement plans, PEO multiple-employer plans and other multiple-employer plans). 
    • Technical and conforming changes have been made to the instructions for multiple-employer plan reporting (e.g., revising the instructions on identifying the “plan sponsor” and “plan administrator”). 
  • Administrative Penalties: The instructions have been updated to reflect an increase in the maximum civil penalty amount assessable under Employee Retirement Income Security Act Section 502(c)(2), as required by the Federal Civil Penalties Inflation Adjustment Act Improvements Act of 2015. 
  • Schedule MB:
    • The instructions for line 3 have been revised to require an attachment that breaks down total withdrawal liability payments made to the plan by date, specifying periodic withdrawal liability amounts and lump-sum withdrawal liability amounts. 
    • Line 4f and its instructions have been clarified. 
    • Line 6e and its instructions have been revised to reflect the movement of the salary scale item to line 6e from line 6f. 
    • Line 6f and its instructions have been revised to require the reporting of the interest rate used to determine the present value of vested benefits for withdrawal liability determinations. 
    • Line 6i and its instructions were moved from line 6e and revised to better understand how expense loads are determined.
    • The instructions for line 8b(1) have been revised to increase the projection period in the attachment to 50 years, for plans with 1,000 or more participants. In addition, benefits projections are broken down between active participants, terminated vested participants and participants in pay-status. 
    • The instructions for line 8b(2) have been revised to require plans to report average accrued monthly benefits as of the valuation date and removed the requirement to provide cash balance account information. 
    • Line 8b(3) and its instructions have been added to require plans with 1,000 or more participants as of the beginning of the plan year to attach a 10-year projection of employer contributions and withdrawal liability payments. The attachments for lines 3 and 8b may be provided in a spreadsheet file (CSV format). 
  • Schedule R: Part V, Line 13 has been revised to require plans to report identifying information about any participating employer who either contributed more than five percent of the plan’s total contributions or was one of the top-ten highest contributors. 
  • Schedule SB: Part VI, Line 26 has been revised and now consists of line 26a and a new line 26b. Line 26a is the same as line 26 from the prior year. Line 26b requires an attachment of a projection of expected benefit payments. The attachments for line 26 may be provided in a spreadsheet file (CSV format). Part IX, line 41 and its instructions, have been replaced to require filers to indicate the first plan year that the extended amortization rule was applied under American Rescue Plan Act of 2021. 

Advance copies of the 2022 Form 5500 series are for informational purposes only and cannot be used to file a 2022 Form 5500 series Annual Return/Report.