DOL Releases Advance Copies of 2025 Form 5500 and Form 5500-SF
Published December 16, 2025
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 2025 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 2025 instructions for each of the forms highlights important modifications to the forms, schedules and instructions.
Changes are summarized below:
- Plan Characteristics Codes: New multiemployer plan characteristic codes, 1J, 1K, and 1L, have been added to the Defined Benefit Pension Features section of Form 5500, Part II, line 8a to identify multiemployer defined benefit plans that during the plan year or in a prior plan year, terminated as a result of mass withdrawal or plan amendment or became insolvent respectively. A new plan characteristic code, 1G, has been added to identify defined benefit plans that use a variable annuity benefit formula. Plan characteristic code 1H (plan covered by PBGC that was terminated and closed out for PBGC purposes) has been modified to clarify that it applies only to terminated single-employer PBGC-covered plans.
- 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 2025 Form 5500 series are for informational purposes only and cannot be used to file a 2025 Form 5500 series Annual Return/Report.