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From my side of the desk, the Form 5434 applications that move cleanly all share the same setup: the applicant has already completed the EA-1 and EA-2F/EA-2L exams, has accounted for the entire last 10 years of actuarial-profession employment on Schedule A, and has lined up the right certifier (immediate supervisor, plus an enrolled actuary if the supervisor is not one). The applications that stall almost always trace back to a missing Schedule A block or a certifier who was not actively enrolled during the period being signed off on.
This guide walks the form the way I walk it with someone applying for enrollment: what each of the 17 line items captures, how Schedule A documents responsible actuarial experience and responsible pension actuarial experience, and how the $680 fee and submission to the IRS Office of Enrollment in Franklin, TN actually work.
Key Takeaways
- Form 5434 is the one-time application to become an enrolled actuary under the Joint Board for the Enrollment of Actuaries; it is authorized by 29 U.S.C. § 1242 and governed by 20 CFR Parts 901 and 902. It is not a tax return.
- The applicant completes 17 numbered line items plus a Schedule A (Employment Record) for each employer or period of employment in the last 10 years.
- Qualifying experience is satisfied by either (1) 36 months of certified responsible pension actuarial experience, or (2) 60 months of certified responsible actuarial experience including at least 18 months of responsible pension actuarial experience – both measured within the 10 years immediately preceding the date of application on Line 17.
- The basic actuarial knowledge requirement (901.12(c)) is satisfied by the Joint Board EA-1 examination(s) or a waiver; the pension actuarial knowledge requirement (901.12(d)) is satisfied by exams EA-2F and EA-2L (or equivalent) within the 10-year period preceding Line 17.
- The $680 application fee is paid electronically at www.pay.gov, or by check or money order payable to the Internal Revenue Service mailed with the form to the IRS Office of Enrollment, 127 International Drive, Room - EA125, Franklin, TN 37067.
What Form 5434 Does and Why It Matters
Form 5434 is the application an actuary files to become an enrolled actuary under ERISA. It is collected by the Joint Board for the Enrollment of Actuaries under the authority of Section 1242, Title 29, United States Code, and processed through the IRS Office of Enrollment in Franklin, TN. Approval gives the applicant the right to perform actuarial services for pension plans subject to ERISA.
The current revision is Form 5434 (Rev. November 2023), OMB Number 1545-0951, Catalog Number 42528L. Before completing it, the applicant should read the regulations at 20 CFR Parts 901 and 902 and the instructions on pages 3-4 of the form. The applicant should not complete Form 5434 until they have satisfied the qualifying experience in section 901.12(b), the basic actuarial knowledge requirement in section 901.12(c), and the pension actuarial knowledge requirement in section 901.12(d).
This is a single, voluntary application – not a recurring tax return. Providing the requested information is, however, required to obtain the benefit of enrollment, and providing false information can subject the applicant to penalties.
Who Completes the Form, and When
- The applicant (the prospective enrolled actuary) completes the entire form: all 17 numbered line items, plus a separate Schedule A for each employer or period of employment in the actuarial profession during the last 10 years.
- The applicant's immediate supervisor signs Schedule A to certify the months of responsible actuarial experience. If the immediate supervisor is not an enrolled actuary and pension actuarial experience is being certified, an enrolled actuary must also sign.
- An enrolled actuary may not certify any period before they were enrolled, or any period during which they were in inactive status.
The form should not be submitted until the applicant has satisfied all three section 901.12 requirements (experience, EA-1 or waiver, and EA-2F/EA-2L). Paper applications are mailed to the IRS Office of Enrollment, 127 International Drive, Room - EA125, Franklin, TN 37067; electronic filing and fee payment is done at www.pay.gov.
How Submission Works
The application is submitted directly to the IRS Office of Enrollment, which administers enrollment on behalf of the Joint Board for the Enrollment of Actuaries. Two filing paths are available:
- Electronic: Complete the form and pay the $680 application fee at www.pay.gov.
- Paper: Complete the form, enclose a check or money order for $680 made payable to the Internal Revenue Service, and mail to: Internal Revenue Service, Office of Enrollment, 127 International Drive, Room - EA125, Franklin, TN 37067.
The Joint Board reviews the application and may, as part of the process, perform a federal tax compliance check on the applicant's Social Security Number to verify timely filing and payment of federal taxes. Failure to provide the requested information could delay or prevent processing.
The 17 Line Items
The applicant completes all 17 numbered items on Form 5434. The form has no separate parts or sections; the items run sequentially from Line 1 through Line 17, followed by one or more Schedule A blocks for the employment record.
Quick Reference Table
| Line | What it captures | Why it matters |
| 1 (a, b, c) | Full legal name – Last, First, Middle | Identifies the applicant on the enrollment roster |
| 2 | Other names used (including maiden name and dates used) | Allows the Joint Board to cross-check prior records |
| 3 | Business name (if using business address) | Routing for correspondence sent to a business location |
| 4 (a-d) | Mailing address (number/street/suite, city, state, ZIP) | Where the Joint Board sends decisions and correspondence |
| 5 | Email address | Secondary contact for the application file |
| 6 | Telephone number | Direct line for application questions |
| 7 | Social Security Number | Used for federal tax compliance check |
| 8 | Date of birth (mm/dd/yyyy) | Anchors the 15-year-or-since-18 lookback on item 14 |
| 9 (A, B, or C) | Enrollment status: first-time, previously denied, or previously enrolled/terminated/resigned | Triggers different attachment requirements |
| 10 (A, B) | Months of responsible actuarial and responsible pension actuarial experience from Schedule A | Tests the 36-month or 60/18-month experience paths |
| 11 (A or B) | Basis for basic actuarial knowledge: EA-1 exam(s) or waiver | Satisfies section 901.12(c) |
| 12 | EA-2F/EA-2L exam(s) and month/year completed | Satisfies section 901.12(d) within the 10-year window |
| 13 | Tax compliance Yes/No for the 3 tax years preceding application | Joint Board may verify via federal tax history |
| 14 | Disreputable conduct Yes/No, 15-year-or-since-18 lookback | Captures findings under section 901.12(f)(1) |
| 15 | Yes/No – ERISA section 411 conviction or false/misleading information finding | Captures grounds for denial under 901.12(f)(2)/(f)(3) |
| 16 | Signature – under penalties of perjury | Declares application true, correct, and complete |
| 17 | Date signed | Anchor date for the 10-year exam and experience windows |
In addition to Lines 1-17, the applicant attaches a separate Schedule A (Employment Record) for each employer or period of employment in the actuarial profession during the last 10 years.
Step-by-Step, Completing Form 5434
Confirm prerequisites first: the qualifying experience in section 901.12(b), the basic actuarial knowledge requirement in section 901.12(c), and the pension actuarial knowledge requirement in section 901.12(d) must all be satisfied before completing the form.
- Download Form 5434 (Rev. November 2023) from the IRS, or open the application on www.pay.gov.
- Complete Lines 1 through 8 (name, address, contact info, SSN, date of birth).
- On Line 9, check the enrollment status box that applies: (A) first-time applicant, (B) previously applied but not granted enrollment, or (C) previously enrolled but enrollment was terminated or resigned. If 9(C) involves discipline, contact the Executive Director before completing the application.
- On Line 10, report total months of responsible actuarial (10A) and responsible pension actuarial (10B) experience – these must reconcile to your Schedule A totals.
- On Line 11, indicate either (A) EA-1 examination(s) or (B) waiver of EA-1. If claiming transition credit for an exam taken prior to January, 2001, indicate so.
- On Line 12, list each EA-2 examination (EA-2F, EA-2L, or equivalent) and the month/year completed – each must be within the 10-year period immediately preceding Line 17.
- On Lines 13, 14, and 15, answer Yes/No for tax compliance (3-year lookback), disreputable conduct under 901.12(f)(1) (15-year-or-since-18 lookback), and ERISA section 411 convictions / false-information findings. Yes answers require detailed attachments.
- Sign Line 16 under penalties of perjury and date Line 17 – this date anchors all lookback periods.
- Complete a separate Schedule A for each employer or period of employment in the actuarial profession during the last 10 years.
Pay the $680 application fee at www.pay.gov, or enclose a check or money order made payable to the Internal Revenue Service and mail with the form to: Internal Revenue Service, Office of Enrollment, 127 International Drive, Room - EA125, Franklin, TN 37067.
The 10-Year Lookback
Two 10-year windows anchor this application, both measured from the Line 17 date of application. The qualifying experience under 901.12(b) must be obtained within the 10 years immediately preceding that date, and the EA-2F/EA-2L exams must be successfully completed within that same 10-year window. The date of successful completion of an exam is the date the applicant sat for the exam, provided a passing grade was received – not the date the grade was published.
Schedule A – The Employment Record
The applicant must account for the entire period of employment in the actuarial profession within the last 10 years on Schedule A – not just the portion that counts as responsible experience. Each Schedule A is a single block; complete a separate block for each employer or period of employment. If employment for a single employer consisted of one period of responsible pension actuarial experience and another period that did not, treat those as separate blocks.
- Block 1: Dates of employment (mm-yyyy)
- Block 2: Employer information
- Block 3: Detailed description of duties – pension plan data, actuarial valuations, special projects, level of involvement with an enrolled actuary, approximate number of valuations, types of plans (ERISA-qualified single-employer/multiemployer, public-sector), specific hours during any part-time periods, and approximate proportion of time per duty type
- Block 4a: Immediate supervisor's name, position title, address, email (if known), and telephone number
- Block 4b: If responsible pension actuarial experience is being certified and the immediate supervisor is not an enrolled actuary, also provide the same information for an enrolled actuary who can certify
- Block 6(A): Months of "responsible actuarial experience" as defined in section 901.1(c)
- Block 6(B): Months of "responsible pension actuarial experience" as defined in section 901.1(e), included in 6(A)
An enrolled actuary may not certify responsible pension actuarial experience for any period before they were enrolled, or for any period during which they were in inactive status.
Two Experience Paths
The qualifying experience requirement is satisfied by either (1) a minimum of 36 months of certified responsible pension actuarial experience, or (2) a minimum of 60 months of certified responsible actuarial experience including at least 18 months of responsible pension actuarial experience. Both paths are measured within the 10-year period immediately preceding the Line 17 date of application. Pension experience is mandatory on both paths.
Tax Compliance, Disreputable Conduct, and ERISA 411 Disclosures
Items 13, 14, and 15 carry the heaviest disclosure obligations on the form. Item 13 asks whether, in any of the 3 tax years preceding the date of application, the applicant failed to timely file a required federal tax return or pay a federal tax – for themselves, a client, or a prospective client – or whether an authoritative body issued a finding of tax evasion against the applicant or a client/prospective client. A Yes answer requires a separate attachment specifying the form number, the taxable period covered, the type and amount of penalties imposed, and whether any outstanding balance remains; if an authoritative body issued an evasion finding, a copy of the finding must be attached.
Item 14 covers conduct findings by an "authoritative body" within the 15-year period preceding the application date (or since the applicant's 18th birthday, if more recent). "Authoritative body" includes courts, licensing/accreditation authorities, federal or state agencies, boards, commissions, hearing examiners, administrative law judges, and other administrative authorities. The conduct list under 901.12(f)(1) includes fraud, dishonesty, breach of trust, knowingly giving false information to Treasury/DOL/PBGC, attempted coercion of those agencies, and abusive or libelous conduct – and the Joint Board may also investigate other disreputable conduct such as exam cheating or violation of professional standards.
Item 15 captures conviction or fines for offenses listed in ERISA section 411 (Section 1111 of Title 29, U.S. Code) – examples include robbery, bribery, extortion, embezzlement, fraud, murder, rape, and perjury under U.S., state, D.C., or U.S. territory law – and any finding that the applicant knowingly submitted false or misleading information in actuarial reports.
Common Mistakes You Can Avoid
Most Form 5434 friction is not the form itself, it is incomplete prerequisites, weak Schedule A documentation, and the wrong certifier. The recurring patterns below are the ones that delay processing or trigger a denial.
A Quick Note on Process Discipline
A clean Form 5434 application comes down to process: every Schedule A block accounted for across the last 10 years, the right certifier signing off, and the disclosure questions answered with the supporting statements attached. Accountably is a U.S. accounting and tax outsourcing and offshoring services company, and the same discipline we bring to compliance work, clear SOPs, clean handoffs, and predictable timelines, is what turns an enrollment checklist into a packet that moves through the Office of Enrollment without rework. We mention our approach here only because process discipline is what keeps these submissions from stalling.
Compliance, Sources, and Last Review
- Authority: Section 1242, Title 29, United States Code – authorizes the Joint Board for the Enrollment of Actuaries to collect this information.
- Regulations: 20 CFR Parts 901 and 902 – read before completing the form (available at www.irs.gov/Tax-Professionals/Enrolled-Actuaries).
- Form revision: Form 5434 (Rev. November 2023), OMB Number 1545-0951, Catalog Number 42528L.
- ERISA section 411 (Section 1111 of Title 29, U.S. Code) – list of offenses that may disqualify an applicant under 901.12(f)(2).
- Paperwork Reduction Act burden estimate: 60 minutes per response. Comments to Joint Board, c/o IRS/Return Preparer Office SE:RPO, Room 3422, 1111 Constitution Avenue, NW, Washington, DC 20224.
Reusable Checklists
These are copy-paste ready for an applicant's enrollment file or a firm's enrolled-actuary onboarding SOP. Items reflect 20 CFR Parts 901 and 902 and the Form 5434 (Rev. November 2023) instructions.
Pre-submission readiness (applicant)
- Confirm the qualifying experience requirement under 901.12(b) is satisfied: either 36 months of certified responsible pension actuarial experience, or 60 months of responsible actuarial experience including at least 18 months of responsible pension actuarial experience – both within the 10 years preceding the Line 17 date.
- Confirm the basic actuarial knowledge requirement (901.12(c)) is satisfied by EA-1 exam(s) or a documented waiver.
- Confirm the pension actuarial knowledge requirement (901.12(d)) is satisfied by EA-2F and EA-2L (or equivalent), both successfully completed within the 10-year window.
- Review tax-filing and payment history for self, all clients, and all prospective clients over the prior 3 tax years for Item 13.
- Identify any authoritative-body findings under 901.12(f)(1) within the prior 15 years (or since age 18) for Item 14.
- Identify any ERISA section 411 convictions/fines, or false/misleading information findings, for Item 15.
Form 5434 line items (1-17)
- Line 1: Full legal name (Last, First, Middle).
- Line 2: Other names used, including maiden name and dates used.
- Line 3: Business name (if using business address).
- Line 4: Mailing address (street, city, state, ZIP).
- Lines 5-6: Email address and telephone number.
- Lines 7-8: Social Security Number and date of birth (mm/dd/yyyy).
- Line 9: Check enrollment status A, B, or C; attach details on a separate page if B or C; contact Executive Director before completing if 9(C) involves discipline.
- Line 10: Months of responsible actuarial (10A) and responsible pension actuarial (10B) experience.
- Line 11: Either A (EA-1 examination(s)) or B (waiver). Indicate transition credit if claiming for an exam taken prior to January, 2001.
- Line 12: List each EA-2 exam and month/year completed.
- Lines 13-15: Tax compliance, disreputable conduct, and ERISA 411/false-information disclosures with attached statements as required.
- Line 16: Sign under penalties of perjury.
- Line 17: Date signed (anchor for all 10-year and 3-year lookbacks).
Schedule A blocks (one per employer / period)
- Account for the entire period of employment in the actuarial profession within the last 10 years – not just the qualifying portion.
- Complete a separate Schedule A for each employer or period of employment; split a single employer into separate blocks if the nature of the experience changed.
- Block 1: Dates of employment in mm-yyyy format.
- Block 3: Detailed duties – pension plan data, valuations, special projects, level of involvement with an enrolled actuary, plan types, hours during part-time periods, and proportional time allocation.
- Block 4a: Immediate supervisor's name, position title, address, email (if known), and telephone number.
- Block 4b: If supervisor is not an enrolled actuary and pension experience is being certified, add the same information for a qualifying enrolled actuary.
- Block 6(A): Months of responsible actuarial experience as defined in 901.1(c).
- Block 6(B): Months of responsible pension actuarial experience as defined in 901.1(e), included in 6(A).
- Verify that any certifying EA was actively enrolled (not inactive) during the period being certified.
Keep Form 5434 From Stalling
An enrolled-actuary application looks light on paper and gets heavy fast in practice. A firm bringing on a new EA may be tracking exam pass dates, Schedule A documentation for 10 years of employment history, and supervisor/EA certifications across multiple past employers. The Form 5434 (Rev. November 2023) instructions assume all three section 901.12 requirements are already met before the form is completed – and that the Schedule A blocks tell a complete, certifiable story for the entire 10-year actuarial-profession window.
The fix is rarely more effort. It is structure: a documented pre-submission checklist, clean ownership of each Schedule A block, and visibility into which periods need which certifiers.
- Treat the EA-2F and EA-2L pass dates as a hard gate – the form should not be completed until those exams are passed within the 10-year window preceding Line 17.
- Build the Schedule A record employer-by-employer for the full 10 years, even periods that will show zero months of responsible experience on Line 6(A).
- For each Schedule A block, identify the certifier before drafting: immediate supervisor by default, plus an enrolled actuary if pension experience is being certified and the supervisor is not an EA.
- Verify each certifying EA's active enrollment dates against the period being certified – no certification for pre-enrollment or inactive periods.
- Pre-stage the Item 13/14/15 attachments early; Yes answers require specific data (form numbers, taxable periods, penalty type/amount, outstanding balance, authoritative body name/address/finding/discipline).
The same operating discipline that keeps an enrolled-actuary application on schedule is what we build for clients who need delivery to hold under load. Accountably brings structured SOPs, named owners, and review checkpoints to U.S. accounting and tax execution – the back-office equivalent of a well-run application process, where nothing important sits in draft while the window closes.
FAQs
What is Form 5434?
Form 5434 is the Joint Board for the Enrollment of Actuaries Application for Enrollment. It is authorized by Section 1242, Title 29, United States Code, and governed by 20 CFR Parts 901 and 902. It is filed once by an actuary applying to become an enrolled actuary under ERISA – it is not a tax return.
How many line items are on Form 5434?
The applicant completes 17 numbered line items (Lines 1 through 17) plus a separate Schedule A (Employment Record) for each employer or period of employment in the actuarial profession during the last 10 years. The form is signed under penalties of perjury on Line 16 and dated on Line 17.
What experience qualifies?
The applicant must have, within the 10-year period immediately preceding the Line 17 date, either (1) 36 months of certified responsible pension actuarial experience, or (2) 60 months of certified responsible actuarial experience including at least 18 months of responsible pension actuarial experience. Pension experience is mandatory on both paths.
What is the application fee, and where is the form filed?
The $680 application fee is paid electronically at www.pay.gov, or by check or money order made payable to the Internal Revenue Service and mailed with the form to: Internal Revenue Service, Office of Enrollment, 127 International Drive, Room - EA125, Franklin, TN 37067.
Who certifies the Schedule A experience?
The immediate supervisor certifies the responsible actuarial experience by default. If the immediate supervisor is not an enrolled actuary and pension actuarial experience is being certified, both the supervisor and an enrolled actuary must sign. An enrolled actuary may not certify any period before they were enrolled, or any period during which they were in inactive status.
When must EA-2F and EA-2L be passed?
The EA-2F and EA-2L exams (or equivalent) must be successfully completed within the 10-year period immediately preceding the Line 17 date of application. The date of successful completion is the date the applicant sat for the exam, provided a passing grade was received – not the date the grade was published.
Does Item 13 cover only personal taxes?
No. Item 13 extends to failures involving the applicant's clients and prospective clients during the 3 tax years preceding the application date, and to authoritative-body findings of evasion against the applicant, clients, or prospective clients. A Yes answer requires a separate attachment with form number, taxable period, penalty type/amount, outstanding balance, and a copy of any finding.