401(k) Fee Benchmarking: What the Public Fee Data Shows, and What It Leaves Out

A fee argument that survives a TPA's review sounds different from one that does not. The weak version says "your plan is expensive." The strong version says "your plan reported this much in administrative expenses per participant, above most plans your size in your industry that year, and here is what that number does not include." The difference is knowing exactly which slice of the bill the public data covers. Disclosure: FiduciarySignal sells the Report Card described below.

What does a 401(k) plan actually pay?

The Department of Labor sorts plan costs into three buckets: "Plan fees and expenses generally fall into three categories: Plan administration fees... Investment fees... Individual service fees." Investment fees are the least visible, because they "are deducted directly from investment returns." Source: DOL, Understanding Retirement Plan Fees and Expenses (as published, read 2026-10-05).

What Form 5500 fee data covers, and what it misses

Sources: 2024 Instructions for Form 5500 (Schedule C, Schedule H line 2i, Schedule I lines 2h and 2i, list of schedules); 2024 Instructions for Form 5500-SF (lines 8f and 8g); DOL 408(b)(2) fact sheet. All as published, read 2026-10-05.

Two lessons sit inside that study. First, total cost needs data the 5500 does not carry. Second, its authors warn that the material "is not intended for benchmarking the costs of specific plans to the broad averages presented here." A broad average is not a benchmark. A benchmark needs a peer group.

How the Report Card benchmarks 401(k) fees

Our fee metric is administrative expense per participant with an account balance: the administrative expenses the plan reported (5500-SF lines 8f plus 8g, Schedule I lines 2h plus 2i, or the Schedule H line 2i total) divided by the participants who hold a balance. The Report Card places that number as a percentile among plans that filed for the same year in the same industry category (one of 20) and participant band (one of seven). On this line, a high percentile means the plan pays more per participant than most of its peers. You get:

• The plan's number beside the peer 25th percentile, median, and 75th percentile
• A trend line of administrative expense per participant against the peer median, year by year
• The fee percentile inside the overall Plan score, inverted so lower cost scores better
• An outreach email draft that cites the plan's cost and the peer median only when the plan sits above the median; below it, the draft leaves the numbers out rather than imply a gap that is not there
• A not-reported label, never a zero, when the filing does not support the calculation

Why divide by participants with a balance? Because those are the accounts the plan administers, including former employees who left money behind. Dividing by active employees only would make plans with many departed participants look more expensive per head than they are.

Percent of assets or dollars per participant?

Fees get quoted two ways, and the choice changes the answer. Percent of assets shows cost relative to the money in the plan; it tends to favor large plans, because, as the ICI study puts it, "there are fixed costs associated with offering a 401(k) plan." Dollars per participant shows what each account costs to administer and holds up better across plans with very different balances. Neither is wrong. They answer different questions, and an honest benchmark says which one it uses.

Free and paid 401(k) fee benchmark tools

If you searched for a free 401(k) fee benchmark, two tools offer one with no signup. Here is what each tool publishes about itself, read on 2026-10-05.

Sources: 401kHunter Fee Checker and methodology; PlanPulseIQ Fee Benchmark; Broadridge fi360 software and technology; ICI/ISS MI DC Plan Profile. All as published, read 2026-10-05.

Credit where it is due: for a sponsor who wants a quick read on their own plan, a free grade or a basis-point calculator is a reasonable start. The question to put to any fee benchmark is the same: compared with whom? The Report Card answers it on every fee line, by industry, size band, and filing year.

How to find 401(k) plans with high fees

• One plan, by hand. Find the filing on the DOL's public EFAST2 Filing Search, add 5500-SF lines 8f and 8g (or read the Schedule H line 2i total), and divide by participants with an account balance. Our Form 5500 search guide walks through the lookup.
• Many plans, in bulk. The DOL Form 5500 datasets hold structured data from every year's filings. Compute the same ratio for every plan and group by industry, size, and year. The data is free; the joining is real work.
• In the Report Card. Open any plan and the fee line already shows its peer percentile, the peer quartiles, and the trend.
• Then check the story. A low administrative number can mean fees ride inside fund expense ratios or that the employer pays them. A high one can reflect a service model the committee chose. Ask before you conclude.

Sources: DOL EFAST2 FAQs and DOL Form 5500 Datasets (as published, read 2026-10-05).

401(k) advisor fee benchmarking

Advisor pay shows up on the 5500 in pieces. On a large plan, fees for investment advice paid from plan assets belong on Schedule H line 2i(5), and an advisor receiving $5,000 or more in direct or indirect compensation appears on Schedule C. On a 5500-SF, advisory fees are folded into line 8f with other administrative service providers. Comparing an advisor's fee with what other advisors charge for similar services is a different dataset, which is what advisor-fee tools such as Broadridge's Fee Benchmarker are built on.

Sources: 2024 Instructions for Form 5500 (Schedule H line 2i(5), Schedule C) and 2024 Instructions for Form 5500-SF (line 8f) (as published, read 2026-10-05).

Where FiduciarySignal fits

FiduciarySignal fits an advisor who wants a defensible, peer-relative read on a plan's reported administrative cost before a meeting, at a published self-serve price. It does not measure fund expense ratios or replace a sponsor's 408(b)(2) disclosures; it shows which reported costs deserve that deeper conversation. FiduciarySignal's All Access plan, which includes the Report Card, is $90 a month after a 7-day free trial (card at checkout, first charge on day 8), or $900 a year billed up front with no trial; see pricing. Built on public DOL EFAST2 Form 5500 data; not affiliated with the Department of Labor.

Related guides

• 401(k) Plan Benchmarking: How a Plan Is Measured Against Its Peers
• Form 5500 Schedule C, Explained for Advisors: Service Codes, Indirect Compensation, and Who Has to File
• 401kHunter: Pricing, What It Does, and a Fair Comparison