Form 5500 Schedule C, Explained for Advisors: Service Codes, Indirect Compensation, and Who Has to File
Sources: DOL, 2025 Instructions for Form 5500, Schedule C (pages 26-30) and the 2025 Schedule C form (observed 2026-10-05).
Search for Schedule C and most of what comes back is written for the person filling it out. This page is written for the person reading it: the advisor, consultant, or TPA who wants to know who a plan pays, how, and how much, before the first meeting. Every rule below comes from the Department of Labor's 2025 instructions and forms, linked so you can check each line against the source.
Who has to file Schedule C?
Schedule C is attached to a Form 5500 filed for a large pension or welfare plan, and for certain pooled filers (MTIAs, 103-12 IEs, DCGs, and GIAs). It is required when any service provider received $5,000 or more in compensation, directly or indirectly, or when an accountant or enrolled actuary was terminated. A plan generally files as large when it covered 100 or more participants at the beginning of the plan year; a defined contribution plan counts participants with account balances, and a plan between 80 and 120 participants may keep last year's category. Small plans, whether they file the Form 5500-SF or the Form 5500 with Schedule I, do not file Schedule C. The schedule is open to public inspection.
Source: DOL, 2025 Instructions for Form 5500 (What To File; 80-120 Participant Rule; Schedule C Who Must File) (observed 2026-10-05).
What's on Schedule C, part by part
| Part and line | What the plan reports | What it tells a reader |
|---|---|---|
| Part I, line 1 | Whether the plan is using the alternative reporting option for providers paid only eligible indirect compensation, and who supplied the required disclosures | Some indirect pay was disclosed to the plan but is not itemized on the filing |
| Part I, line 2 | Each person paid $5,000 or more in total direct and indirect compensation, most highly compensated first: name, EIN, codes, relationship, direct pay, and indirect pay that is not eligible indirect compensation | The provider roster and the money, in order of size |
| Part I, line 3 | For fiduciaries and providers of contract administration, consulting, custodial, investment advisory, investment management, brokerage, or recordkeeping services: each source of indirect pay of $1,000 or more, or a formula | Who pays the provider behind the scenes, such as a fund company |
| Part II, line 4 | Fiduciaries or providers who failed or refused to give the information Part I needs | A provider the plan could not get fee information from |
| Part III | Termination of an accountant or enrolled actuary during the plan year, with an explanation and any material disagreement | The plan's own account of why its accountant or actuary left |
Source: DOL, 2025 Instructions for Form 5500, Schedule C Parts I-III (pages 26-30) (observed 2026-10-05).
Schedule C service codes
Element (b) of each line 2 entry carries every code that describes both the service and the type of compensation, so one provider can carry several. These are the service codes in the 2025 instructions:
| Code | Service |
|---|---|
| 10 | Accounting (including auditing) |
| 11 | Actuarial |
| 12 | Claims processing |
| 13 | Contract Administrator |
| 14 | Plan Administrator |
| 15 | Recordkeeping and information management (computing, tabulating, data processing, etc.) |
| 16 | Consulting (general) |
| 17 | Consulting (pension) |
| 18 | Custodial (other than securities) |
| 19 | Custodial (securities) |
| 20 | Trustee (individual) |
| 21 | Trustee (bank, trust company, or similar financial institution) |
| 22 | Insurance agents and brokers |
| 23 | Insurance services |
| 24 | Trustee (discretionary) |
| 25 | Trustee (directed) |
| 26 | Investment advisory (participants) |
| 27 | Investment advisory (plan) |
| 28 | Investment management |
| 29 | Legal |
| 30 | Employee (plan) |
| 31 | Named fiduciary |
| 32 | Real estate brokerage |
| 33 | Securities brokerage |
| 34 | Valuation (appraisals, etc.) |
| 35 | Employee (plan sponsor) |
| 36 | Copying and duplicating |
| 37 | Participant loan processing |
| 38 | Participant communication |
| 40 | Foreign entity (e.g., an agent or broker, bank, insurance company, etc. not operating within jurisdictional boundaries of the United States) |
| 49 | Other services |
Schedule C compensation codes
| Code | Type of compensation |
|---|---|
| 50 | Direct payment from the plan |
| 51 | Investment management fees paid directly by plan |
| 52 | Investment management fees paid indirectly by plan |
| 53 | Insurance brokerage commissions and fees |
| 54 | Sales loads (front end and deferred) |
| 55 | Other commissions |
| 56 | Non-monetary compensation |
| 57 | Redemption fees |
| 58 | Product termination fees (surrender charges, etc.) |
| 59 | Shareholder servicing fees |
| 60 | Sub-transfer agency fees |
| 61 | Finders' fees/placement fees |
| 62 | Float revenue |
| 63 | Distribution (12b-1) fees |
| 64 | Recordkeeping fees |
| 65 | Account maintenance fees |
| 66 | Insurance mortality and expense charge |
| 67 | Other insurance wrap fees |
| 68 | "Soft dollars" commissions |
| 70 | Consulting fees |
| 71 | Securities brokerage commissions and fees |
| 72 | Other investment fees and expenses |
| 73 | Other insurance fees and expenses |
| 99 | Other fees |
Source: DOL, 2025 Instructions for Form 5500, Schedule C element (b) code list (pages 28-29) (observed 2026-10-05).
Direct vs. indirect compensation on Schedule C
Direct compensation is paid by the plan itself: out of a plan account, from forfeiture or fee-recapture accounts, from the trust before allocation, or charged to participant accounts. Indirect compensation comes from someone other than the plan or the sponsor but is earned because of services to the plan. The DOL's examples include fees charged against mutual funds, collective trusts, and insurance separate accounts and reflected in the plan's investment: management fees, sub-transfer agency fees, shareholder servicing fees, account maintenance fees, and 12b-1 distribution fees. Finders' fees, float revenue, brokerage commissions, and soft dollars count too.
The truth is, one exclusion matters more to a prospector than any other: payments made directly by the plan sponsor that the plan does not reimburse are not reportable on Schedule C. If an employer pays its advisor or TPA out of company funds, that relationship can be invisible here.
What is eligible indirect compensation?
A narrower category that lets a plan skip itemizing some indirect pay. It covers fees or expense reimbursements charged to investment funds and reflected in the investment's value, finders' fees, soft-dollar revenue, float revenue, and brokerage commissions or other transaction-based fees not paid directly by the plan or sponsor. It qualifies only if the plan received written materials disclosing the compensation's existence, the services it pays for, the amount or formula, and who pays and receives it. When both conditions hold, the plan answers Yes on line 1 and names the source of the disclosures instead of listing each recipient. A provider that also received any other kind of pay must still be listed on line 2 if it crossed the $5,000 line.
Source: DOL, 2025 Instructions for Form 5500, Schedule C line 1 and indirect compensation (pages 26-28) (observed 2026-10-05).
Which schedule shows provider fees, and where is the broker commission?
| If you want | Look at | Who files it |
|---|---|---|
| Who was paid, by name, and how much | Schedule C, Part I | Large plans |
| Commissions and fees paid to insurance agents and brokers, by name | Schedule A, Part I, lines 2 and 3 | Form 5500 filers with insurance contracts, large or small |
| Administrative expenses by category: contract administrator, recordkeeping, audit, investment advisory and management, trustee and custodial, actuarial, legal, and others | Schedule H, lines 2i(1) through 2i(12) | Large plans |
| One line for administrative service providers (salaries, fees, and commissions) | Schedule I, line 2h | Small plans filing the Form 5500 |
| Total insurance fees and commissions, no names | Form 5500-SF, line 10e | Small plans on the short form |
Two cross-schedule rules trip readers up. Commissions and fees already listed on Schedule A are not repeated on Schedule C, but they still count toward a provider's $5,000 threshold. And Schedule H's expense lines report what the plan paid by category, not who received it; the names live on Schedule C.
Sources: 2025 Schedule A, 2025 Schedule H, 2025 Schedule I, and 2025 Instructions for Form 5500-SF (observed 2026-10-05).
What Schedule C can't tell you
- Anything about most small plans. For plan years ending in 2023, the DOL reports that 641,689 of 724,720 401(k)-type plans had fewer than 100 participants, per its Private Pension Plan Bulletin (Tables A1 and A1(b)). Plans that size generally file without a Schedule C.
- Every fee. Providers under the threshold, sponsor-paid bills, and eligible indirect compensation reported only through line 1 all fall outside the line 2 roster.
- The full fee agreement. Under the DOL's 408(b)(2) disclosure rule, covered service providers furnish their service and compensation disclosures in writing to the plan's responsible fiduciary. Those documents go to the plan; Schedule C is the public, after-the-year summary.
- Today's lineup. A return is due the last day of the seventh calendar month after the plan year ends, plus up to two and a half months on extension, so Schedule C always describes a finished year.
How to read Schedule C before a first meeting
- Read line 2 top to bottom. The order is by compensation, so the largest relationships come first.
- Separate direct from indirect pay for each provider. A provider paid mostly through fund revenue is a different conversation from one billed to the plan.
- Read element (c), the relationship. An affiliate of the recordkeeper or an employee of the sponsor changes how you read a fee.
- Check line 3 for the payers behind indirect compensation.
- Open Schedule A if there is an insurance contract, so you don't miss the broker.
- Bring one line to the meeting, not ten. A sponsor can verify a single fact from its own filing in its own paperwork, and that is a better opener than a fee lecture.
Schedule C, decoded for you
Full disclosure, this part is paid. FiduciarySignal's 401(k) Report Card reads each plan's own Form 5500 and lays out the provider roster next to administrative cost against comparable peers, participation, and compliance red flags, in plain English you can use on a call. It inherits every limit above: no Schedule C on the filing means no Schedule C roster in the software either. FiduciarySignal is $90 per month after a seven-day free trial, or $900 per year. It is built on public DOL EFAST2 data and is not affiliated with the Department of Labor. If you are starting from a sponsor's name rather than a filing, the free DOL lookup is walked through in Form 5500 search.
Related guides
- How to Find the Advisor and Recordkeeper on a 401(k) Plan (Free, From the Form 5500)
- Form 5500 Prospecting: What a Plan's Filing Tells You — and What It Can't
- Form 5500 Search: The Free Tools, Step by Step — and the One Thing a Filing Can't Tell You
Frequently asked questions
What is Schedule C on Form 5500?
Schedule C (Service Provider Information) is where a large plan reports the people and firms it paid for services. Part I lists each provider that received $5,000 or more in direct or indirect compensation, with service and compensation codes. Part II lists providers that failed or refused to supply information. Part III reports the termination of an accountant or enrolled actuary.
Source: DOL, 2025 Instructions for Form 5500, Schedule C (pages 26-30) (observed 2026-10-05).
Do small 401(k) plans file Schedule C?
No. Schedule C is required for large plans and certain pooled filers. Small plans, generally those with fewer than 100 participants at the beginning of the plan year, file the Form 5500-SF or the Form 5500 with Schedule I, and neither includes Schedule C.
What are the Schedule C service codes?
Two-digit DOL codes for the service a provider performed and the type of pay it received. Service codes run from 10 (accounting, including auditing) to 49 (other services); for example, 15 is recordkeeping, 26 and 27 are investment advisory, and 33 is securities brokerage. Compensation codes run from 50 (direct payment from the plan) to 99 (other fees), including 63 for 12b-1 distribution fees and 64 for recordkeeping fees.
What is indirect compensation on Schedule C?
Pay a provider receives from someone other than the plan or the plan sponsor because of its services to the plan, such as mutual fund management fees, sub-transfer agency and shareholder servicing fees, 12b-1 fees, finders' fees, float, soft dollars, and brokerage commissions. "Eligible" indirect compensation is a subset the plan may report in summary on line 1 if it received written disclosures about it.
Which Form 5500 schedule shows broker commissions?
For commissions on insurance contracts, Schedule A: line 2 gives total commissions and fees, and line 3 names each agent or broker paid. Schedule C covers other providers, and commissions already on Schedule A are not repeated there. Small plans on the Form 5500-SF report only a total of insurance fees and commissions on line 10e, with no names.
Is there a dollar threshold for Schedule C reporting?
Yes. A provider must be listed in Part I, line 2 if it received $5,000 or more in total direct and indirect compensation in connection with services to the plan during the plan year. On line 3, each source of indirect compensation of $1,000 or more must be identified for fiduciaries and certain service types.
Source: DOL, 2025 Instructions for Form 5500, Schedule C lines 2 and 3 (pages 26-29) (observed 2026-10-05).
Read any plan's provider roster without decoding Schedule C yourself.
Built on 8.9M public Form 5500 filings. Back-tested against the next year's filings. Self-serve.
See a Plan's Report Card