Filing the Form 5500 is half the job. Participants may be owed a summary of it.
A plan that files a Form 5500 generally has to give participants a Summary Annual Report within nine months of the plan year end. Small plans that must file may be able to use the short Form 5500-SF. Many small welfare plans do neither, but that depends on facts employers often get wrong.
A plain-language summary of the filing.
The rule is in 29 CFR 2520.104b-10.
Who Gets One
Participants in a plan that files an annual report. Welfare plan beneficiaries who are only receiving benefits are not on the list.
When
Within nine months after the plan year closes, or within two months after the end of any extension the plan has been granted for the annual report.
What It Says
A summary taken from the plan’s most recent Form 5500, on the form the regulation prescribes for welfare plans, with a notice of participants’ right to get the full report on request.
The short form for small plans that must file.
It is not an option for every small plan, and it is not for large ones.
The Size Test
Fewer than 100 participants at the start of the plan year. A plan that filed as a small plan the year before can stay small up to 120 participants.
Other Conditions
No employer securities, 100 percent eligible plan assets, qualification for the audit waiver, and no Form M-1 requirement. Multiemployer and pooled plans cannot use it.
Deadlines
The last day of the seventh month after the plan year ends, with a one-time extension of up to two and a half months by filing Form 5558 before the due date.
The small plan exemptions, and where they stop.
Unfunded, fully insured, or combination welfare plans with fewer than 100 participants at the start of the plan year are exempt from filing.
Why the Exemption Fails
A welfare plan is not unfunded if it takes participant contributions outside the applicable relief, or holds assets in a trust or separate fund. Such a plan has to look at whether it can file the 5500-SF.
The SAR Exemptions
The SAR rule exempts totally unfunded welfare plans and welfare plans that meet the small plan exemption in 29 CFR 2520.104-20(b), among others.
The Common Mistake
The exemption from filing does not touch the summary plan description. Every plan needs one regardless of size.
Form 5500 small plan exemption → Form 5500 due date calculator →
What employers ask about Summary Annual Reports.
Is the SAR the same as the SPD?
No. The SPD describes the plan. The SAR summarizes the annual financial report the plan filed. Both are participant disclosures.
How do we deliver it?
By the methods the disclosure rules allow, including electronic delivery that meets the conditions. Many employers send it with an annual notice.
Who prepares the 5500?
Usually a third-party preparer or the carrier’s compliance group. Confirm who owns each filing and each participant notice before the due date.
Related guides.
Form 5500 Small Plan Exemption
When a small plan does not have to file.
Form 5500 Due Date Calculator
Your filing deadline by plan year.
Participant Requests for Plan Documents
What participants can ask for and when.
Tell us which filings you rely on someone else for.
We’ll tell you which filings and participant notices your plan owes, who prepares them today, and where the handoffs tend to break. No cost, and no obligation.
Number of participants at the start of the plan year
Insured or self-funded
Who prepares your Form 5500
Your last filed return
Rough answers are fine. We build the numbers from there.
Laws and rules referenced
29 CFR 2520.104b-10 — Summary annual report: who must furnish it, timing, content and exemptions.
DOL: 2025 Instructions for Form 5500-SF — Who may file the short form, deadlines and extensions.
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