Form 5500 Audit Requirement Calculator100-Participant Test and 80-120 Rule

Does this plan need an audited financial statement filed with its Form 5500?

Small plan or large plan from the participant count and the prior-year filing, with the 80-120 participant election and the audit consequence.

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Your figures
Example figuresIllustrative only. Type over them with your own.
Audit consequence
Small-plan filing: the accountant examination is waived only if the conditions in 29 CFR 2520.104-46 are met.
What the participant count means for the audit
Category by participant count (100 or more is large)
Large plan
All results
MeasureResult
Category by participant count (100 or more is large)Large plan
Category for this filing
80-120 rule: with a prior-year return filed as a small plan, you may elect the same category.
Small plan (election available)
Audit consequence
Small-plan filing: the accountant examination is waived only if the conditions in 29 CFR 2520.104-46 are met.
How this was worked out
Work shownrecomputed as you type
Large plan if participants at the start of the plan year are 100 or more, otherwise small plan
80-120 rule: if the count is 80 to 120 and a Form 5500 was filed for the prior plan year, the filer may elect the prior year category

Illustrative arithmetic on the figures you enter. Check the result against your firm's methodology before relying on it.

The formulas

  • Large plan if participants at the start of the plan year are 100 or more, otherwise small plan
  • 80-120 rule: if the count is 80 to 120 and a Form 5500 was filed for the prior plan year, the filer may elect the prior year category

How it works

The Form 5500 instructions treat a plan that covered 100 or more participants as of the beginning of the plan year as a large plan. A defined contribution pension plan uses the number on line 6g(1), the participants with account balances at the beginning of the plan year, except that a first return uses the line 6g(2) number.

Under the 80-120 participant rule, when the number of participants is between 80 and 120 and a Form 5500 was filed for the prior plan year, the filer may elect to complete the return in the same category as the prior year. A short plan year of seven months or less and participation in a DCG reporting arrangement carry their own rules, which this tool does not apply.

Illustrative figures only. Check the result against your firm's methodology before relying on it.

Common questions

Which participant count do I use for a 401(k) plan?

Line 6g(1), participants with account balances at the beginning of the plan year, except that a first return uses line 6g(2).

Does a small plan always avoid the audit?

No. The waiver in 29 CFR 2520.104-46 depends on conditions, including qualifying plan assets or bonding.

Sources

Runs in your browser. The figures you type are not sent to CORAA or stored. Check the result against your firm's methodology before relying on it.

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