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ARTICLE · 13 NOVEMBER 2026

Ask The Experts: Which Participants Should 403(b) Sponsors Include On Their Plan’s Form 5500?

Groom Law Group, Chartered
Groom Law Group, Chartered
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Groom Law Group, Chartered

Groom Law Group, Chartered

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Plan sponsors face important distinctions when counting participants for Form 5500 filings, particularly following 2023 regulatory changes that affect how eligible employees with zero account balances are treated. Understanding which participant counts apply to different sections of the form is critical for accurate compliance reporting.

United StatesEmployment and HR

In PLANSPONSOR’s Ask the Expert series, Groom attorneys Kimberly Boberg, Kelly Geloneck, Emily Gerard, and David Levine discuss how plan sponsors should count participants when preparing Form 5500 filings.

The column explains that while changes effective in 2023 generally exclude eligible employees with zero account balances from the participant count used to determine large or small plan filing status, those employees may still need to be included in other Form 5500 participant counts. The authors emphasize the importance of following the specific instructions for each line of the form.

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