How to Complete and File Form 5500 Schedule C: Service Provider Information

Form 5500 Schedule C is the attachment that large employee benefit plans use to report every service provider that received $5,000 or more in compensation from the plan during the year, along with any provider that refused to disclose fees and any accountant or enrolled actuary the plan terminated. It is filed as part of the Form 5500 package through EFAST2, and it has three parts that each answer a different question the Department of Labor wants answered about who was paid, who wouldn’t say, and who was let go.¹

Who Has to File Schedule C

Schedule C is required for any employee benefit plan filing the full Form 5500, meaning plans with 100 or more participants at the beginning of the plan year.² That covers both pension and welfare plans. Small plans that file Form 5500-SF do not complete Schedule C at all.

Direct Filing Entities such as master trusts, common or collective trusts, and group insurance arrangements also complete Schedule C when they file their own Form 5500.³ A plan that invests through a filing DFE gets some relief because the DFE reports compensation at its level, but only when the DFE actually files.

Part I: Reporting Service Provider Compensation

Part I is the heart of the schedule. You list every person or entity that received, directly or indirectly, $5,000 or more in total compensation connected to the plan during the year.⁴ Compensation is money or anything else of monetary value, not just direct cash. If one provider receives several kinds of fees, add them together to see whether it crosses the $5,000 line.

Identifying Each Provider

For each reportable provider, enter the name and Employer Identification Number. If the individual listed has an employer with an EIN, use the employer’s EIN. A self-employed provider without an EIN may give an address and telephone number instead. Do not substitute a Social Security number for an EIN.⁵

You also assign one or more service codes describing the work. The DOL maintains a standard list running from code 10 through code 54. Common ones include:⁶

10 for accounting, including auditing
11 for actuarial work
15 for recordkeeping and information management
27 for plan investment advisory services
28 for investment management
29 for legal work
33 for securities brokerage
49 for other services

A provider that plays more than one role, such as a firm handling both recordkeeping and investment advisory duties, gets all applicable codes on the same entry.

Direct Versus Indirect Compensation

Direct compensation is paid straight from plan assets. It shows up in bank statements and invoices and is usually easy to track.

Indirect compensation is harder. It includes 12b-1 fees, finder’s fees, float income, soft-dollar revenue, and commissions paid by investment funds to a provider who works with the plan. Under 29 CFR 2550.408b-2, covered service providers must disclose these arrangements to the responsible plan fiduciary reasonably in advance of entering into the contract.⁷ Those 408(b)(2) disclosures are your source for the indirect amounts you enter on Schedule C. When a provider’s indirect fees change, the provider must furnish updated information, and the new figures need to appear on the next filing.

Eligible Indirect Compensation

Some indirect compensation gets a simplified reporting path. Eligible indirect compensation, or EIC, means fees or expense reimbursements charged to an investment fund and reflected in the value of the plan’s investment or its return.⁸ Qualifying vehicles include mutual funds, bank common and collective trusts, insurance company pooled separate accounts, and separately managed accounts holding a single plan’s assets.

When compensation qualifies as EIC and the plan received the required disclosures, such as through a mutual fund prospectus that spells out the fees and reflects them in the fund’s return, you do not list the individual provider on Schedule C or separately report the dollar amounts. That is a meaningful shortcut for plans invested in funds with many sub-advisors and distribution agents.

Two traps sit inside this rule. Fees not disclosed in a fund prospectus or not reflected in the fund’s return do not qualify as EIC. And when an intermediary such as a broker receives payment from a fund and passes part of it downstream to a recordkeeper, the downstream payment loses EIC status even though the original fee was disclosed in the prospectus.⁸ Ordinary fund operating expenses such as attorneys’ fees and printers’ fees charged against the fund are not reportable indirect compensation.

Part II: Providers Who Refused to Disclose Fees

Part II is where you name a service provider that failed or refused to supply the fee information you needed for Part I. Identify the provider by name, EIN, and address to the extent you can.⁹ Filling in Part II protects the plan administrator from liability for the missing data and alerts the DOL to a provider that may be violating its 408(b)(2) obligations.

Do not leave Part II blank for convenience. If a provider is unresponsive and you omit them from both Part I and Part II, the DOL can hold the plan administrator responsible for the gap. Keep a record of your outreach, including emails, letters, and follow-up calls, that shows you tried to obtain the information.

Part III: Terminated Accountants and Enrolled Actuaries

If the plan replaced its accountant or enrolled actuary during the year, Part III asks for the terminated professional’s name, EIN, position, address, telephone number, and an explanation of the change.⁹ The DOL watches this section for red flags. A plan that fires its auditor shortly before a filing may signal disagreements over financial reporting.

Routine departures, such as a firm merger, a retirement, or a vendor switch for cost reasons, need only a short factual explanation. If the termination followed a dispute over accounting treatment or actuarial assumptions, describe the disagreement honestly. Vague language like “business reasons” attached to a real conflict tends to invite follow-up.

Filing Through EFAST2

Schedule C is submitted as part of the Form 5500 package through EFAST2, the DOL’s electronic filing system at efast.dol.gov.¹⁰ EFAST2 credentials now use Login.gov; the older EFAST2 User ID and password system is no longer available. Build in time to set up Login.gov linked to EFAST2 before the deadline.

The plan administrator must electronically sign the filing, certifying under penalty of perjury that the information is true and complete. A missing signature is the single most common reason a filing gets a Processing-Stopped error.¹¹

Deadline and Extension

Form 5500, with Schedule C attached, is due by the last day of the seventh month after the plan year ends. For a calendar-year plan, that is July 31.¹² To get more time, file Form 5558 before the original due date for an automatic extension to the 15th day of the third month after the normal due date, which is October 15 for a calendar-year plan.¹³

Common Validation Errors

After upload, EFAST2 runs validation checks and returns either Accepted or an error. Beyond the missing-signature problem, watch for these:¹¹

EIN or plan number mismatches. The EIN on Form 5500 Line 2b must be consistent year to year, and the three-digit plan number and EIN on every attached schedule, including Schedule C, must match the main form. Unauthorized plan numbers such as 888 or 999 trigger a rejection.
Reporting period gaps. The beginning date of the current filing must be the day right after the ending date of the prior year’s filing.
Date mismatches on schedules. Plan year dates on all attached schedules (other than Schedule P) must match Part I of Form 5500.
Final-return inconsistencies. Marking a filing as a Final Return/Report while still reporting assets or participants at year-end stops processing.

Fix any errors and resubmit. EFAST2 issues a tracking number and status report for each submission so you can confirm the corrected filing was accepted.

Penalties for Late or Incomplete Filings

Late or missing filings can draw penalties from both the DOL and the IRS, and the two run in parallel rather than as alternatives.

The DOL can assess civil penalties under ERISA section 502(c)(2) for each day a required filing is overdue. The penalty is adjusted annually for inflation, but the DOL did not issue a new inflation adjustment for 2026, so the 2025 amounts remain in effect.¹⁴ The IRS separately imposes a penalty under IRC section 6652(e) of $250 per day, up to $150,000, for each late Form 5500.¹⁵

Reducing Penalties Through Voluntary Correction

The DOL’s Delinquent Filer Voluntary Compliance Program offers sharply reduced penalties for plan administrators who come forward with late filings before the DOL contacts them. The basic penalty under the program is $10 per day, with caps that vary by plan size:¹⁶

Small plans: $750 per late filing, capped at $1,500 per plan. Plans sponsored by a 501(c)(3) tax-exempt organization have a lower per-plan cap of $750.
Large plans: $2,000 per late filing, capped at $4,000 per plan.

Participating in DFVCP requires waiving the right to challenge the penalty amount. The program covers DOL penalties only. It does not shield you from IRS penalties under the Internal Revenue Code or from penalties under Title IV of ERISA.

Records to Keep

ERISA section 107 requires plan fiduciaries to retain the records supporting Form 5500 filings, including the underlying documentation for Schedule C, for at least six years from the date the report was filed or was due, whichever is later.¹⁷ Keep the filed Form 5500 and Schedule C along with the service provider agreements, 408(b)(2) disclosures, invoices, and fee statements you used to prepare the schedule. Six years is the floor. For records tied to ongoing benefit obligations such as trust and custody agreements, holding them until all benefits have been paid and any audit window has closed is the safer practice.

1
U.S. Department of Labor. Schedule C (Form 5500) Service Provider Information
2
eCFR. 29 CFR 2520.103-1 – Contents of the Annual Report
3
U.S. Department of Labor. Direct Filing Entity Bulletin User Guide
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U.S. Department of Labor. Schedule C (Form 5500) Service Provider Information
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U.S. Department of Labor. Instructions for Form 5500 Annual Return/Report of Employee Benefit Plan
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U.S. Department of Labor. Instructions for Form 5500 Annual Report
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eCFR. 29 CFR 2550.408b-2 – General Statutory Exemption for Services or Office Space
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U.S. Department of Labor. Frequently Asked Questions About the 2009 Form 5500 Schedule C
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U.S. Department of Labor. Schedule C (Form 5500) Service Provider Information – 2024
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U.S. Department of Labor. Welcome – EFAST2 Filing
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U.S. Department of Labor. EFAST2 Form 5500 and Form 5500-SF Filing Tips
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Internal Revenue Service. Form 5500 Corner
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Internal Revenue Service. Form 5558 – Application for Extension of Time to File Certain Employee Plan Returns
14
AIHA. DOL Cancels This Year’s Inflation Adjustment to Civil Penalties
15
Internal Revenue Service. Penalty Relief Program for Form 5500-EZ Late Filers
16
U.S. Department of Labor. Delinquent Filer Voluntary Compliance Program
17
U.S. Department of Labor. Where Are the Plan Records? Recordkeeping in the Electronic Age