What Is a Group of Plans?

A Group of Plans (GoPs) is a regulatory classification introduced by the U.S. Department of Labor (DOL) that allows multiple retirement plans—specifically defined contribution plans like 401(k)s—to file a single, consolidated Form 5500. This structure is designed to reduce administrative burdens and promote cost efficiencies for employers while preserving each participating plan’s independence and fiduciary structure. GoPs represent an evolution in the landscape of retirement plan administration and reflect the DOL’s ongoing efforts to modernize retirement reporting and compliance.

Background and Regulatory Context

The concept of GoPs emerged from the Setting Every Community Up for Retirement Enhancement (SECURE) Act of 2019, which aimed to improve retirement savings access for American workers. The SECURE Act instructed the DOL to explore ways to streamline the Form 5500 filing process. In response, the DOL proposed and finalized rules that introduced the GoP model, enabling certain defined contribution plans to participate in group filings starting with the 2022 plan year.

It’s important to note that a Group of Plans is distinct from other types of multi-plan arrangements such as Multiple Employer Plans (MEPs) or Pooled Employer Plans (PEPs). While MEPs and PEPs involve shared plan sponsorship and fiduciary oversight, GoPs allow each employer to maintain a separate plan with its own fiduciary responsibility and administrative structure. The key unifying element is the shared filing of a single Form 5500, subject to strict eligibility criteria.

Eligibility Requirements

For a group of plans to qualify as a GoP, all participating plans must meet specific requirements outlined by the DOL:

1. Same Plan Administrator and Named Fiduciary: All plans must have the same individual or entity serving as the plan administrator and named fiduciary under ERISA.
2. Identical Plan Year: Each plan in the group must operate on the same plan year. This ensures that reporting aligns on a uniform timeline.
3. Same Plan Type: Only defined contribution plans (such as 401(k) plans) of the same type may be included. Defined benefit plans are excluded from GoP eligibility.
4. Consistent Investments and Trustee: All plans must offer the same investment options and use the same trustee. This uniformity supports the ability to consolidate reporting without compromising data integrity.
5. Individual Plan Maintenance: Each employer retains its own plan document and plan structure. The GoP is purely a reporting mechanism—not a merged or pooled plan arrangement.

These requirements are designed to balance administrative efficiency with transparency and compliance oversight. If any of the participating plans deviate from the required structure, the group will not qualify to file as a GoP.

Reporting and Operational Features

The most significant feature of a Group of Plans is the shared filing of Form 5500, which is used to report plan financials, compliance information, and operational data to the DOL, IRS, and PBGC. Under a GoP, a single Form 5500 is filed on behalf of all participating plans, with accompanying schedules detailing the unique characteristics of each plan.

This includes:

• Basic identifying information for each participating plan (e.g., employer, EIN, plan number)
• A summary of assets, liabilities, and operations for each plan
• Required schedules, such as Schedule C (service provider information) and Schedule H (financial statements), consolidated where applicable

While the consolidated reporting streamlines compliance, it also requires precise coordination among participating employers and service providers to ensure the accuracy and consistency of information.

Benefits and Considerations

The primary benefit of participating in a GoP is administrative efficiency. By consolidating the Form 5500 filings, employers may reduce compliance costs, simplify audit requirements, and enhance operational consistency across plans. For plan administrators and recordkeepers managing multiple similar plans, a GoP can streamline workflows and reduce redundancy in reporting.

However, GoPs also introduce complexity in coordination. Employers must ensure they meet all eligibility requirements annually and maintain alignment on plan features, service providers, and investment options. A breakdown in consistency—such as a change in investment lineup or plan year—could disqualify the group from GoP treatment.

Additionally, because GoPs are not fiduciary arrangements themselves, each employer remains fully responsible for its own plan’s compliance under ERISA. This distinguishes GoPs from MEPs or PEPs, where some fiduciary functions may be outsourced or centralized.

The Bottom Line

A Group of Plans (GoP) is a regulatory structure that enables multiple defined contribution plans to file a consolidated Form 5500, streamlining retirement plan reporting without merging plan governance. GoPs are suitable for employers and service providers managing multiple similar plans who seek administrative efficiency without sacrificing individual plan control. While not a fiduciary vehicle, GoPs represent an important compliance innovation aligned with the SECURE Act’s broader goal of improving retirement plan access and administration.