401(k) Plan Benchmarking: How a Plan Is Measured Against Its Peers
Hand a plan sponsor a number and you get a polite nod. Hand them the same number next to a few dozen plans their size, in their industry, from the same filing year, and you get a question. That is benchmarking. Full disclosure: FiduciarySignal sells the Report Card described below, so hold our rows to the same standard as everyone else's.
What is 401(k) plan benchmarking?
Two different products answer to the name. An industry benchmark study publishes averages for a sector or size range. A plan-level benchmark places one plan inside a distribution of comparable plans and tells you where it sits, say the 30th percentile on participation and the 80th on administrative cost. Only the second tells you about the plan across the table, and only if the peer group is right. A 40-participant dental practice and a 4,000-employee manufacturer do not run the same plan, so a defensible benchmark matches on industry, plan size, and filing year.
Is 401(k) benchmarking required?
The Department of Labor frames it as a duty, not a method. Its 408(b)(2) fact sheet says responsible plan fiduciaries "must ensure that arrangements with their service providers are 'reasonable' and that only 'reasonable' compensation is paid for services." Its employer guidance adds: "An employer should document its selection and monitoring process," with a formal review "at reasonable intervals." A peer benchmark is one way to document that review, which is why an advisor who brings one starts a fiduciary conversation, not a pitch.
Sources: DOL EBSA fact sheet, Final Regulation Relating to Service Provider Disclosures Under Section 408(b)(2) and DOL ERISA Fiduciary Advisor, selecting and monitoring service providers (as published, read 2026-10-05).
Where 401(k) benchmark data comes from
Three sources feed plan benchmarking, and they are not interchangeable. When anyone says "benchmark," ask which one they mean.
| Source | Who sees it | What it covers | What it leaves out |
|---|---|---|---|
| Form 5500 and 5500-SF | The public, through the DOL EFAST2 Filing Search | Assets, participants, contributions, distributions, administrative expenses paid by or charged to the plan; large plans add Schedule C, listing providers paid $5,000 or more | Fund expense ratios; payments the employer makes directly that the plan does not reimburse |
| 408(b)(2) disclosures | The responsible plan fiduciary, from each covered provider expecting at least $1,000 | Services, plus direct and indirect compensation | There is no 408(b)(2) schedule in the Form 5500 series, so they never reach a public filing search |
| Fund expense data | Fund companies and data vendors | Expense ratios, deducted from fund returns | Plan-level administration costs |
Sources: 2024 Instructions for Form 5500 (Schedule C filers, the $5,000 threshold, the sponsor-paid exclusion, the list of schedules); DOL 408(b)(2) fact sheet (the $1,000 threshold); DOL, Understanding Retirement Plan Fees and Expenses (investment fees "are deducted directly from investment returns"); DOL EFAST2 FAQs (public Filing Search). All as published, read 2026-10-05.
The Report Card's benchmarks use the first source only: Form 5500 data. Public and standardized is the strength; the limits are spelled out below.
How the 401(k) Report Card builds a peer group
- Industry. The first two digits of the business code on the filing map to one of 20 categories, from Agriculture and Construction through Healthcare, Professional Services, and Public Administration.
- Plan size. Seven participant bands: 1–25, 26–50, 51–100, 101–250, 251–500, 501–1,000, and more than 1,000.
- Filing year. A plan is compared with plans that filed for the same year, never a blend of years.
For each peer group and metric we store a nine-point distribution (1st through 99th percentile) and interpolate between those points, so a plan lands at, say, the 63rd percentile instead of in a coarse bucket. If an industry-and-size group holds fewer than five plans, it widens to every industry in that size band and is labeled broadened. A peer counts toward a metric only when its own filing reports that metric's inputs.
| Metric | How it is computed from the filing | Better when |
|---|---|---|
| Investment return | Investment income as a share of plan assets | Higher |
| Administrative expense per participant | Administrative expenses paid from the plan, divided by participants with an account balance | Lower |
| Average participant contribution | Participant contributions per active participant | Higher |
| Average employer contribution | Employer contributions per active participant | Higher |
| Participation rate | Participants with a balance divided by active participants, capped at 100% | Higher |
| Average account balance | Plan assets per active participant | Higher |
| Distributions per participant | Benefit distributions per active participant | Lower |
| Corrective distributions | Corrective distributions per active participant | Lower |
| Terminated participants | Share of all participants who are not active | Lower |
The percentiles roll into a Plan score out of 100, flipped for the four lower-is-better metrics so a high score always reads as good. It appears only when at least five metrics are reported; an unreported metric is left out, never filled in with a zero. Each number sits beside the peer 25th percentile, median, and 75th percentile, with a trend line against the peer median and the plan's Form 5500 red flags. For the meeting: charts, talking points, an outreach email draft from the plan's own filing, and .docx reports, which download after the trial (capped monthly, unlimited on annual).
What a 401(k) benchmark report cannot tell you
Here's the cold hard truth about any benchmark built from public filings, ours included: it is exactly as complete as the filing.
- Fund expense ratios. Investment fees are deducted from fund returns, not reported as a plan expense. Low administrative cost can sit on top of expensive funds.
- What the employer pays. Expense lines report costs paid by or charged to the plan, and Schedule C excludes sponsor payments the plan does not reimburse. A sponsor who pays the recordkeeper directly can look inexpensive on paper.
- Small-plan detail. Schedule C is attached for large plans. A 5500-SF filer reports administrative costs as two totals, lines 8f and 8g.
- Timing. A Form 5500 is due "the last day of the seventh month after the plan year ends (July 31 for a calendar year plan)," per the IRS, later with a Form 5558 extension. A filing benchmark describes last year's plan.
- Context. A plan at the 85th percentile on cost may have chosen a richer service model. A benchmark starts the question; it does not answer it.
Sources: DOL, Understanding Retirement Plan Fees and Expenses; 2024 Instructions for Form 5500 (Schedule C, Schedule H line 2i); 2024 Instructions for Form 5500-SF (lines 8f and 8g); IRS Form 5500 Corner (due date, Form 5558). All as published, read 2026-10-05.
Who sells 401(k) plan benchmarking
Several vendors benchmark plans from public filing data. Here is what each publishes about its own product, read on 2026-10-05.
| Tool | What it benchmarks, as published | Price, as published |
|---|---|---|
| Judy Diamond's 401(k) Benchmark Report 2026 | An industry study: "27 industry verticals across 8 different performance metrics," from "over 680,000 401(k) plans," organized by size of firm | By request; no price on its page |
| Judy Diamond Retirement Plan Prospector+ | A Plan Score Card against "other plans in the country, state, same industry or with similar asset levels or participant counts," plus custom peer groups | National Edition listed at $3,900/Year |
| ERISApedia Plan Data Intelligence ReSource | A Word-file benchmark report against "176 peer groups (updated monthly)" on "eight highly relevant metrics," included at no additional cost; your logo with a two-user subscription | $2,087 (1 user) to $4,175 (5 users), annual |
| 401kHunter | A per-plan unlock of "Schedule H & C detail, fee grade, peer benchmarks"; it also describes "client-ready and white-label benchmarking reports" | 10 credits per unlock at 10¢ a credit; Pro listed at $100/mo |
| MarketPro Retirement powered by BrightScope (ISS Market Intelligence) | Institutional distribution intelligence across "797K DC plans," with 10+ years of trended plan-level data | Demo request; no published price |
| FiduciarySignal 401(k) Report Card | Nine metrics as peer percentiles by industry, size band, and filing year, plus a Plan score | FiduciarySignal: $90/month after a 7-day free trial, or $900/year |
Sources: Judy Diamond's 401(k) Benchmark Report, Retirement Plan Prospector+ and its store; ERISApedia Plan Data Intelligence and pricing; 401kHunter pricing and llms.txt; ISS MarketPro Retirement powered by BrightScope. All as published, read 2026-10-05.
Credit where it is due: Judy Diamond's study gives sector-wide context, ERISApedia's report is an editable Word file that can carry your logo, 401kHunter opens one plan's benchmarks for a handful of credits, and ISS serves institutions sizing whole markets.
Looking for BrightScope's free 401(k) plan ratings? When we checked on 2026-10-05, brightscope.com redirected to issmarketintelligence.com and the per-plan rating URL we tested returned HTTP 404. That is one dated check of one URL, not proof that no rating page survives. More on our BrightScope page.
Source: brightscope.com and a BrightScope 401(k) rating URL (observed 2026-10-05).
How to benchmark a 401(k) plan, step by step
- Pull two or three filing years. One filing is a snapshot; three show a direction. Our Form 5500 search walkthrough shows how.
- Fix the peer group first. Industry, participant band, filing year, decided before you look, so the comparison cannot drift toward the answer you hoped for.
- Compare per participant. Raw dollars scale with headcount.
- Treat outliers as questions. Beyond the 75th or below the 25th percentile is something to ask about, not a verdict.
- Say the limits first. The 5500 does not show fund expense ratios or employer-paid fees. Saying so makes the rest credible.
Where FiduciarySignal fits
FiduciarySignal fits an advisor who wants a plain-English peer read on any plan from its public filing, at a published self-serve price. It is not a fund-lineup or expense-ratio benchmark and does not replace a sponsor's 408(b)(2) disclosures; pair the two when a committee asks for total plan cost. 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) Fee Benchmarking: What the Public Fee Data Shows, and What It Leaves Out
- 401(k) Plan Red Flags: The Form 5500 Lines That Show Them, and How to Raise Them Fairly
- BrightScope in 2026: Where the 401(k) Ratings Went
Frequently asked questions
What is 401(k) benchmarking?
Measuring a plan's numbers against comparable plans, so a fee or participation rate becomes a position rather than a raw figure. Peers should match on industry, plan size, and filing year. FiduciarySignal's Report Card does this from the plan's own Form 5500, metric by metric, as peer percentiles.
What is a 401(k) plan benchmark report?
A document that sets one plan's reported metrics (fees, participation, contributions, balances, investment return) beside a peer group's median and range. Reports built from Form 5500 data, ours included, cover administrative expenses paid from the plan, not fund expense ratios or 408(b)(2) detail. Ask any vendor what the peer group is.
Is 401(k) plan benchmarking required by law?
The DOL frames the requirement as a duty rather than a method: responsible plan fiduciaries must ensure service arrangements are reasonable and that only reasonable compensation is paid, and employers should review providers at reasonable intervals and document the process. A peer benchmark is one common way to document that review.
Sources: DOL 408(b)(2) fact sheet and DOL ERISA Fiduciary Advisor (as published, read 2026-10-05).
Where did the BrightScope 401(k) plan ratings go?
BrightScope's name now appears on MarketPro Retirement powered by BrightScope, an ISS Market Intelligence platform sold to institutions by demo request. When we checked on 2026-10-05, brightscope.com redirected to issmarketintelligence.com and the per-plan rating URL we tested returned HTTP 404. That is one dated check, not proof that every rating page is gone.
Source: ISS MarketPro Retirement powered by BrightScope and brightscope.com (observed 2026-10-05).
Do the Report Card's benchmarks include fund expense ratios or 408(b)(2) fees?
No. Its fee metric is administrative expenses paid from the plan, per participant with an account balance, as reported on the Form 5500. Fund expense ratios are deducted from investment returns, and 408(b)(2) disclosures go from providers to the plan fiduciary, not into a public filing. For total plan cost, combine the benchmark with the sponsor's disclosures.
How much does FiduciarySignal's 401(k) Report Card cost?
The Report Card is part of FiduciarySignal's All Access plan: $90 a month after a 7-day free trial (card at checkout, first charge on day 8), or $900 a year billed in full with no trial. Report downloads open after the trial, capped on monthly and unlimited on annual.
Put any plan's Form 5500 next to its peers: same industry, same size band, same filing year.
Built on 8.9M public Form 5500 filings. Back-tested against the next year's filings. Self-serve.
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