How to read Schedule A broker compensation

What Form 5500 Schedule A reports about broker commissions and fees, what it leaves out, a worked example, and how to use it in a renewal conversation.

If your company sponsors an insured benefit plan, the insurers' reports of what they paid your broker are public. They sit in Schedule A of Form 5500. This guide explains what is in that schedule, how this site summarizes it, and what it cannot tell you. General information only, not advice.

What Form 5500 and Schedule A are

Most employee benefit plans covered by ERISA file an annual Form 5500 with the Department of Labor (DOL). Under the 2024 Form 5500 instructions, a Schedule A must be attached for every plan that has to file if any benefits are provided by an insurance company or similar organization, such as a health maintenance organization. There is one Schedule A per insurance contract. Contracts that are administrative-services-only (ASO) arrangements do not get one.

The carrier, not the broker, supplies most of the Schedule A information. That is useful: it is a second source, separate from what your broker tells you.

The lines that matter

• Line 1: the carrier, the contract number, the approximate number of people covered at the end of the contract year, and the policy dates.
• Line 2: the total of insurance fees and commissions attributable to the contract.
• Line 3 (Part I): each agent, broker or other person paid, listed in descending order of amount, with name and address, the sales and base commissions paid, the fees paid, the purpose of the fees, and an organization code (code 3 is "insurance agent or broker").

The instructions say commissions here are amounts charged directly to the contract and paid to a licensed agent or broker for the sale or placement of the contract. Everything else goes in the fees column: service fees, consulting fees, finder's fees, and profitability and persistency bonuses, among others. Where a payment depends on the value of the policies placed or retained, including bonuses, the pro rata share belonging to your contract is to be reported.

How this site summarizes it

We take the DOL's published data for the 2024 plan year and group rows by broker name and ZIP code. For each listed broker we show:

• the number of distinct plan filings naming the broker;
• total commissions and total fees reported;
• the average per filing, and where the total and average fall among all listed brokers, expressed as percentiles only;
• the median number of participants in the plans.

We do not label any amount high, low or fair. A percentile says where a figure sits among listed brokers, nothing more.

A worked example (illustrative numbers)

Suppose a made-up employer, Example Co., buys a medical policy with annual premium of $400,000. Its Schedule A shows a commission of $20,000 to Broker X and no fees. A quick calculation: $20,000 divided by $400,000 is 5 percent of premium. That figure is only a starting point. It tells you the size of the payment relative to the premium. It does not tell you whether the services were worth it.

Now suppose next year premium rises to $440,000 and the commission is $22,000. Both moved by 10 percent. If the broker's work was the same, you might ask whether the pay should track premium. That is a fair question to put to the broker. It is a question, not a finding.

Now suppose Broker X also reports $6,000 of fees labeled "consulting". Ask what the consulting was and whether it overlaps with the service already covered by commission.

Why a bigger number is not a verdict

A broker serving many large plans will show large totals, and one serving a few small plans will show small ones. Compensation also varies by product (health, life, disability and retirement contracts are priced differently), by carrier, and by whether the broker is paid by commission, fee or both. Two brokers with the same total may do very different work, and the data cannot say which gives better value.

What Schedule A leaves out

• Fees your company pays the broker directly are not on the carrier's Schedule A.
• The instructions exclude some items from reporting, for example payments by the insurer for administrative work that is not tied to selling or renewing the policy, and occasional low-value gifts or meals.
• Self-funded plans with ASO contracts do not file this schedule.
• It does not describe services, advice quality or outcomes.
• Names and addresses are as typed on the form, so one firm may appear under several offices or spellings, and names are limited to 35 characters in the data.

Using it in a renewal conversation

1. Pull your own Schedule A for the last two or three years (see how to find your plan's Form 5500).
2. Add up what your broker told you it is paid. Compare it with line 2 and line 3.
3. Ask about any fee line, bonus or other carrier on the schedule that you did not expect.
4. Ask in writing for the broker's full compensation, including amounts from carriers or vendors that are not on your schedule, using questions to ask your benefits broker.
5. Read how broker compensation works to place what you hear in context.

Other disclosures

Separately, ERISA section 408(b)(2) requires covered service providers who reasonably expect $1,000 or more in compensation to give the plan's responsible fiduciary written disclosure of services and of direct and indirect compensation, reasonably in advance of entering into, extending or renewing the contract. The Consolidated Appropriations Act, 2021 extended this kind of disclosure to brokers and consultants serving group health plans. Read the statute or DOL guidance, or ask counsel, to see how it applies to you. Source for the data: DOL Form 5500 datasets.

Updated 2026-10-02.

General information only, current as of the date above. The information on Benefits Broker Atlas is not a recommendation or a guarantee of anyone's work. A license record shows registration status on the date shown, not workmanship, insurance coverage at the time of your job, or suitability for your project. Confirm license, insurance and permits directly before you hire. Rules and programs change; check the official sources linked in this guide.