Summary Annual Report for employee benefit plans

By Elizabeth Walker on December 19, 2025 at 11:00 AM

If you’re an employer offering various employee benefit plans, it's essential to understand your responsibilities regarding compliance and taxes. If the federal government requires your organization to file Form 5500 with the Department of Labor (DOL) for your benefit plan, you must also deliver the Summary Annual Report (SAR) to plan participants.

The SAR is relatively simple to fill out once you’ve completed Form 5500. However, some employers may not be aware that the federal government requires it and could face costly penalties if they fail to distribute it.

This article explains what the SAR is, who must complete it, and how you should provide it to your employees.

In this blog post, you’ll learn:

What the Summary Annual Report (SAR) is, how it relates to Form 5500, and why ERISA requires you to provide it for certain employee benefit plans.

Which employers and benefit plans must distribute the SAR, which plans are exempt, and who must receive the report annually.

What information the SAR must include, and the penalties employers may face for failing to distribute it to their employees.

What is the Summary Annual Report?

The SAR is an annual summary of important information on Form 5500 for benefit plan participants and beneficiaries. This document gets its name from Form 5500, also known as the Annual Report.

Not only does the SAR summarize each year’s Form 5500, but it also provides transparency by keeping covered individuals informed of their plan’s financial health on an annual basis. Additionally, it outlines their rights to certain information as a participant in the benefit.

Under the Employee Retirement Income Security Act of 1974 (ERISA), employers offering specific health and retirement benefit plans must file Form 5500 and distribute the SAR or be subject to penalties¹.

Who must distribute the Summary Annual Report?

ERISA-covered plans that require the filing of Form 5500 also require completion of the SAR.

These plans include:

Large insured plans
Retirement plans
Pensions
Certain group health and employee welfare benefit plans, such as medical insurance, dental insurance, and disability benefits.

Employers offering alternative health benefits, such as individual coverage health reimbursement arrangements (ICHRAs), group coverage HRAs (GCHRAs), and flexible spending accounts (FSAs), must also comply with ERISA, Form 5500, and SAR annual reporting requirements if they meet the minimum participant and funding thresholds.

Group health plans with 100 or more participants on the first day of the plan year must file Form 5500. Small plans with fewer than 100 participants can sometimes file Form 5500-SF instead².

Who is exempt from distributing the Summary Annual Report?

If you’re not required to file Form 5500, you don’t have to complete the SAR.

Plans exempt from Form 5500 include:

Plans provided by government entities and churches
Any plan maintained primarily for compliance with unemployment
Disability, or workers' compensation
Plans that are entirely maintained outside of the U.S. for non-U.S. citizens

Welfare plans with fewer than 100 participants and small unfunded plans (where the employer pays all benefit claims using their general assets) are also generally exempt from SAR requirements.

What must employers include in the Summary Annual Report?

The SAR is a summary of the information you included on Form 5500 for plan participants. If your plan doesn’t require you to include certain information on Form 5500, you don’t need to include it on the SAR.

Below is the basic information you must include on the SAR for health and welfare plans to comply with federal regulations³:

Basic business information
- Include the name of your plan, your EIN, and the type of plan you offer. You’ll also need to provide the time period that the report covers, which should be the previous plan year.
Funding arrangements and insurance information
- List the insurance carrier contact information, the types of claims the insurer will pay, and the total amount of premiums paid to the insurance carrier for the entire plan year if your plans are insured.
- Indicate the types of claims the plan sponsor agreed to pay for if your plans aren’t insured.
Basic financial information of the plan
- List the value of plan assets at the beginning and end of the benefit plan year. This includes any increases or decreases in plan assets throughout the year.
- Include the total amount of paid plan expenses, administrative expenses, and plan benefits paid to participants.
- List the plan’s total income, including employee contributions, employer contributions, gains and losses, and investment earnings.
Plan participants’ rights to information
- Inform plan participants that they can request a copy of Form 5500 and any attached items and examine them at the plan’s main office. The SAR must describe the attached items.
- Participants also have the right to request an annual statement of the plan’s assets, liabilities, income, and total plan expenses.
Rights to additional information
- Include how benefit participants can obtain a copy of the SAR from the Department of Labor⁴.
- Describe how non-English speaking participants can receive assistance obtaining a copy of the SAR in their native language. Write these instructions in the non-English language and include them in the English version of the SAR.
- Employee pension benefit plans that don’t meet the Small Pension Plan Audit Waiver Regulations must disclose this information on the SAR⁵.

If you need to include extra information to accurately summarize your Form 5500, add it to the SAR with the heading “Additional Explanation.”

Who receives the Summary Annual Report?

Plan administrators don’t need to file the SAR with the DOL, Internal Revenue Service (IRS), or other government agencies. Instead, you must provide it to all participants listed in the plan’s summary plan description (SPD) annually.

Benefit participants and beneficiaries include:

Active employees and retirees
Former participants who lost coverage during the plan year
Former participants who continued their health coverage with COBRA
Alternate recipients under a qualified medical child support order
Widows or other beneficiaries of deceased participants
Representatives of incapacitated individuals in any of the above categories

When must employers distribute the Summary Annual Report?

You must distribute the SAR to plan participants no later than nine months after the plan year ends, which is two months after the deadline to file Form 5500. For example, suppose your benefit is on a calendar plan year. In that case, the annual filing deadline for Form 5500 is generally July 31, and the SAR distribution deadline is September 30.

If you request and receive an extension of time to file Form 5500, you must distribute the SAR within two months after the extension period ends. For example, if you have a calendar year plan, the filing extension deadline for Form 5500 is October 15. This means the extended deadline to distribute the SAR is December 15.

How can employers distribute the Summary Annual Report?

Although you provide the SAR to plan participants for informational purposes only, you must prepare it using the proper style, format, and content requirements outlined by the U.S. Department of Labor. You must also ensure your distribution method results in the actual delivery of the SAR to your applicable employees.

Plan administrators can distribute the SAR using the following methods:

By hand
By mail
In a company newsletter or other company publication for employees
Electronic distribution
- The federal government permits you to use this method if the participant has consented to electronic delivery or you follow DOL e-disclosure requirements and safe harbors.

Additionally, all plan participants have the right to request a copy of the SAR at any time from the plan administrator.

What are the penalties for not distributing the Summary Annual Report?

Failing to distribute the SAR is a violation of ERISA regulations. If a plan participant or beneficiary requests a copy of the SAR and doesn’t receive it within 30 days of that request, you may incur fines of up to $110 per day until you provide them with a copy⁴. This is a per-occurrence fine for every employee who requests a SAR but doesn’t receive one within the 30-day timeline.

Conclusion

Employers who have filled out Form 5500 know it’s a challenging yet essential tax form to complete. Luckily, the SAR is less of a hassle to tackle. By following the guidelines in this article, you’ll be on your way to completing the SAR accurately, distributing it to plan participants, and avoiding penalties.

The annual reporting requirements can seem daunting if this is your first time offering employee benefits. If you need help filling out Form 5500 or the SAR, contact a tax advisor or a third-party administrator to help you complete both forms compliantly and answer any further questions.

This post was originally published on January 2, 2024. It was last updated on December 19, 2025.

This article is not intended as tax advice. Please consult with a licensed professional for assistance with understanding your specific Form 5500 and SAR obligations.