Form 5500 Schedule C Explained: Service Provider Fees

What is Schedule C of Form 5500?

Form 5500 Schedule C is the "Service Provider Information" schedule. On it, a plan reports every person or firm that received $5,000 or more in direct or indirect compensation in connection with services to the plan during the year — the recordkeeper, custodian, trustee, investment advisor, broker, TPA, accountant/auditor, actuary, and legal counsel — along with how much each was paid and how.

Because the filing is public, Schedule C of Form 5500 is the only place you can see, for free, what a comparable employer's plan pays its providers. You can read any large plan's Schedule C in a Form 5500 lookup.

Who files Schedule C

Schedule C is filed by large plans (those filing the full Form 5500, generally 100+ participants). Plans filing the short Form 5500-SF do not file Schedule C — which is why small-plan service providers aren't in the public record. Health & welfare plans that meet the limited exemption at 29 CFR 2520.104-44 (unfunded/insured) also don't file it.

The $5,000 reporting threshold

A service provider must be listed if it received $5,000 or more in total compensation (directly or indirectly) in connection with services to the plan. Providers paid less than that de-minimis amount may not appear, so Schedule C captures the meaningful relationships, not every vendor. The $5,000 test is measured against the total the provider received, not a per-plan slice.

Direct vs. indirect compensation

Schedule C splits a provider's pay into two buckets — and the indirect bucket is where the fees most plan sponsors never see live:

• Direct compensation — paid from plan assets to the provider (e.g., recordkeeping fees deducted from the trust, or charged to participant accounts).
• Indirect compensation — received from sources other than the plan or sponsor but tied to plan services: revenue sharing, 12b-1 distribution fees, sub-transfer agency fees, shareholder servicing fees, float revenue, finder's fees, and "soft dollars." These are charged against an investment fund and reflected in its returns, so participants pay them without a separate invoice.

Eligible indirect compensation (EIC) and the alternative reporting option

Some indirect compensation can be reported in summary form as "eligible indirect compensation" (EIC) — fees charged to an investment fund and reflected in its value, finder's fees, soft dollars, float, and brokerage/transaction fees — but only if the plan received written disclosures describing the compensation, the services, the amount or formula, and who paid and received it. If those disclosures exist, the plan can use the alternative reporting option (Schedule C, line 1) instead of itemizing each amount.

For each fiduciary or key provider (contract administrator, consultant, investment advisor/manager, broker, custodian, or recordkeeper), any source paying $1,000 or more of indirect compensation must be separately identified.

Service categories and codes you'll see

Each provider is reported with official service codes (10–49) and compensation codes (50–99). We bucket those into plain-language categories so you can scan a plan's lineup at a glance:

• Recordkeeper, Custodian/Trustee, Investment Advisor/Consultant
• Accountant/Auditor, Actuary, TPA/Administrator
• Broker, Legal counsel, Insurance, and Other

For the full, official list of every Schedule C service and compensation code (and what each number means), see the Form 5500 codes reference.

Parts II and III: missing info and terminations

Part II lists any provider that failed or refused to give the plan the information needed to complete Part I. Part III reports the termination of an accountant or enrolled actuary during the plan year, with an explanation — a useful signal when researching a plan's audit history.