ICHRA Reporting Part 2 of 3: Compliance Form 5500

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Table of Contents


Welcome back to Zorro’s 2023 compliance miniseries!

Today, we’ll dive deeper into the world of ICHRA reporting and review Form 5500, an ERISA annual reporting requirement for employer benefit plans – including ICHRA. 

Form 5500 serves as an annual report about a plan sponsor’s benefit plan's financial condition, investments, and operations. With ICHRA, it's important to note that filing this form is mandatory if your plan covers 100 or more participants at the start of the plan year.

<blog-icon-title>What's Inside Form 5500<blog-icon-title>

Form 5500 asks for specific information about the ICHRA plan:

  • Total Number of Participants: drawing distribution in counts between employees who received reimbursements and those who were eligible but did not.
  • Total Amount of Reimbursements: the aggregate of all reimbursements provided throughout the year.
  • Plan Characteristics: codes that indicate various features of your ICHRA.
  • Financial Information: including assets at the beginning and end of the year, total income, and expenses.
  • Insurance Information: details about the insurance contracts under the plan, including premiums paid, total benefits paid, and reserves.

There are nuances within the data included in each of the above and what to report on a per-employee as well as on an overall, employer level. 

<blog-icon-title>Sub-Variants of Form 5500<blog-icon-title>

  • Form 5500-SF: A shorter version of the 5500, designed for small benefit plan sponsors that meet certain requirements.
  • Form 5500-EZ: Specifically for one-participant plans that aren't subject to the requirements of Title I of ERISA.

<blog-icon-title>Deadlines (and other bits to remember)<blog-icon-title>

Form 5500 is due seven months after the close of your plan year. So, if your plan year corresponds to the calendar year, your deadline is July 31st of the following year. 

Extensions are available, but be sure to request them as late submissions can result in penalties from the DOL and the IRS! The IRS can charge you up to $250 per day, while the DOL penalties can be up to $1100 per day - adding up to a combined potential maximum of $150,000 per year! 


While Form 5500 might seem like tedious paperwork, its significance in ICHRA compliance can't be understated. Accurate and timely submissions offer transparency and ensure your plan operates within the regulatory framework. As always, the intricacies matter! Tackling the nuances requires a robust technology platform – and guess what? Zorro is here to streamline the process for you.

Get the smart, transparent benefits solution that you've been waiting for.

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