Updated August 13, 2026. Quick answer: Schedule C is the page of your 401(k) plan’s annual federal filing that names every service provider paid $5,000 or more out of the plan, and what each one was paid. It is public, and you can look up your own employer’s. It also has three large holes that are easy to miss: it excludes anything your employer paid directly, it excludes insurance commissions reported elsewhere on the same filing, and its indirect-compensation figures are mostly blank — 86.85% of large 401(k) plans flag a provider as receiving indirect compensation and only 19.62% report a dollar amount.
What this page is: a plain reading of what Schedule C of the Form 5500 does and does not disclose, quoted to the instructions, plus how to find your own plan’s.
As of: the 2023 Form 5500 instructions, the current edition for plan year 2023 filings, read 2026-08-13. Incidence figures are measured across the 50,483 401(k) plans in our study of the same filings.
What Schedule C is
Every year, an employer running a retirement plan files a Form 5500 with the Department of Labor. If the plan is a large plan — broadly, 100 or more participants at the start of the year — it files the full Form 5500 with schedules attached. Smaller plans generally file the shorter Form 5500-SF instead: the instructions say that “if you are a small plan (generally under 100 participants at the beginning of the plan year), you may be eligible to file the Form 5500-SF instead of the Form 5500.”
Schedule C is the service-provider page of the full filing. The instructions state when it is required: it “is required for a large plan, MTIA, 103-12 IE, DCG or GIA if (1) any service provider who rendered services to the plan or DFE during the plan or DFE year received $5,000 or more in compensation, directly or indirectly from the plan or DFE, or (2) an accountant and/or enrolled actuary has been terminated.”
Part I lists the providers and what they were paid. That is the part with the money in it, and it is the part everything below is about.
What it discloses — and what it leaves out
Direct compensation is the number with teeth. The instructions define it as “Payments made directly by the plan for services rendered to the plan or because of a person’s position with the plan” — and they give examples that tell you whose money it is: direct payments out of a plan account, charges to forfeiture and fee-recapture accounts, charges to the trust before allocation, and direct charges to individual participant accounts.
Then the sentence that decides what the schedule can be used for: “Payments made by the plan sponsor, which are not reimbursed by the plan, are not subject to Schedule C reporting requirements even if the sponsor is paying for services rendered to the plan.” If your employer pays the recordkeeper out of its own pocket, that cost is simply not here. A low Schedule C is not proof of a cheap plan; it may be proof of a generous employer. Two plans cannot be compared on this figure as though it were their total cost.
Insurance commissions are carved out. For plans required to file Part I, “commissions and fees listed on the Schedule A are not required to be reported again on Schedule C.” They still count toward the $5,000 test — the instructions are explicit that the Schedule A amount “must, however, be taken into account in determining whether the agent’s, broker’s, or other person’s direct or indirect compensation in relation to the plan or DFE is $5,000 or more” — but the dollars sit on a different schedule. Insurance-based arrangements are systematically undercounted by anyone adding up Schedule C alone.
Indirect compensation is disclosed in principle and blank in practice. Indirect compensation is what a provider receives from someone other than the plan or sponsor in connection with the plan — revenue sharing, 12b-1 fees, sub-transfer-agency payments and the like. But providers who received only what the instructions call “eligible indirect compensation” need complete only line 1 of Part I, so they never appear with a figure at all. In the 50,483 large 401(k) plans we measured, 43,842 plans (86.85%) flag at least one provider as receiving indirect compensation, and only 9,907 (19.62%) report any indirect dollar amount — a median of $13,351 where reported. No credible total of indirect compensation can be built from this file, and we do not publish one.
Anyone paid under $5,000 is invisible, by design.
How to read your own plan’s filing
Form 5500 filings are public. The instructions say so plainly: a filing is “posted by the Department of Labor on the Internet for public disclosure.” Filings are made and published through the EFAST2 system at efast.dol.gov, and the bulk extracts researchers use — including the ones behind our study — are published in DOL’s Form 5500 datasets directory at askebsa.dol.gov.
Four things worth knowing before you read one:
- Find the right plan year. Filings arrive months after the plan year ends, and amended filings keep arriving for years. The most recent complete year is usually two years back.
- Read Part I, Item 2 line by line. Each row is one provider: the relationship, the service codes, and the direct compensation. The median large 401(k) plan names 2 providers here; the 90th percentile names 4.
- Read the codes as a mixed list, not a job title. The instructions ask filers to “Select from the list below all codes that describe both the kind of services provided and the type of compensation received. Enter as many codes as apply” — one combined list covering both. Codes in the 10–49 range name the service (15 is recordkeeping and information management, 27 is investment advisory (plan)); codes from 50 up name the type of payment (64 is recordkeeping fees, 63 is distribution (12b-1) fees). A single row often carries several of each.
- The “relationship” column is not a role. It describes the provider’s relationship to your employer, not what they do for the plan, and it is free text. Overwhelmingly it says nothing useful.
For scale, across the large 401(k) plans in our study the most common entries by incidence are recordkeeping fees (77.5% of plans), participant loan processing (57.1%), investment advisory (plan) (48.4%) and recordkeeping and information management (48.0%).
Four ways this data misleads careful people
1. Averages are worthless here. Across all 51,498 401(k) filings we joined that report any direct compensation, the mean ratio of provider compensation to plan assets is 16,040 basis points against a median of 25 — because a small number of plans report real compensation against an end-of-year asset figure at or near zero. Use medians.
2. The most expensive plans are mostly plans that are closing. Final filings are 0.05% of the plans we analysed but 4.13% of those paying more than 5% of assets. Any “worst plans” list built without excluding terminating plans is a list of wind-ups.
3. Zero direct compensation does not mean free. Plans that name providers and report nothing paid directly are paying them some other way — indirectly, or by the employer.
4. It is self-reported. No one audits these entries for accuracy. Treat a single plan’s figures as what that plan said, not as an established fact.
Related
What 401(k) plans pay their service providers, by plan size is the study built from these filings — 50,483 plans, plan year 2023. Researching the funds in your 401(k) covers the other half of the bill, the fund expense ratios Schedule C never touches. No advertising appears on this page and we earn nothing from it.