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.