401(k) Advisor Fees: What’s Average, What’s High, and How to Benchmark Them

A data-driven guide to 401(k) advisor fees using 2024 Form 5500 benchmarks, plan-size medians, and the DOL’s Schedule C advisory service categories.

401(k) Advisor Fees: What’s Average, What’s High, and How to Benchmark Them

If you are trying to benchmark 401(k) advisor fees, start with this: there is no giant national advisor-only benchmark that works the same way as an all-in 401(k) fee benchmark. The cleanest advisor-only evidence comes from Schedule C compensation disclosures on full annual Form 5500 filings, and that sample naturally skews toward larger plans.

That matters because small-plan advisor pricing usually looks higher in basis points than large-plan pricing. Minimum fees, fixed governance work, and lower asset balances all push the effective advisor percentage up for smaller plans. So if you want a defensible answer to “what is a normal advisor fee,” you need to read advisor-only disclosures where they exist, but you also need to benchmark them against the broader all-in plan-cost ranges by plan size.

That is why this page uses a two-step framework. First, it explains what the advisor-only Schedule C data can and cannot tell you. Second, it uses the broader 2024 all-in 401(k) fee benchmark as the outer boundary for what a plan can plausibly be paying once recordkeeping, administration, investments, audit, and legal costs are added on top of the advisor layer.

Quick answer: what counts as average, and what counts as high?

For most plan sponsors, the cleanest answer is this: advisor fees should be judged in the context of plan size, fiduciary scope, and total plan cost. A fee that looks ordinary for a small 401(k) can look expensive for a larger one, and a quote that looks fine in isolation can look aggressive once you compare it against the right plan-size benchmarks.

The most common mistake is comparing an advisor quote to a benchmark without checking whether the benchmark is advisor-only or all-in. The public benchmark above is all-in plan cost. Your advisor fee is only one layer inside it, alongside recordkeeping, administrative, custody, investment, audit, and legal expenses.

The new advisor-only Schedule C dataset is still useful, but it needs to be framed carefully. It is a narrow subset of plans that filed a full annual Form 5500 and disclosed advisor compensation on Schedule C, which means it is naturally skewed toward larger plans and underrepresents the small-plan market. That makes it helpful for directional benchmarking and scope analysis, but not reliable enough to treat as the one national headline average for all 401(k) advisor fees.

What Form 5500 and Schedule C can actually tell you about advisor fees

The current public benchmark pages tell you what plans paid in total. To get closer to advisor-specific compensation, you need to read the plan’s latest Schedule C and map the advisor work to the service codes disclosed there. In this repo’s DOL service-code taxonomy, the advisor-related codes include:

That matters because not every advisor is doing the same job. One advisor may be limited to investment recommendations for the committee. Another may take discretion as a 3(38) investment manager. Another may focus on participant advice, plan design, fee benchmarking, or vendor oversight. Those are different scopes, and they should not be benchmarked as if they were interchangeable.

There are also two practical caveats. First, Schedule C only captures service-provider relationships that clear the DOL reporting threshold, so the absence of a line item does not automatically mean the plan has no advisor. Second, some investment-related costs can be embedded elsewhere in the fee structure rather than sitting neatly on one advisor line. Third, the cleanest advisor-only averages come from plans that file a full annual Form 5500 with usable Schedule C compensation detail, which in practice skews the sample toward plans with at least 100 participants. Because sub-100 plans are more likely to be missing from that advisor-only sample and usually pay higher effective basis-point fees due to fixed minimums, any published advisor-only average will naturally look cheaper than what many small plans actually pay. That is why the best benchmarking workflow is to compare all-in plan fees, then reconcile the advisor-specific disclosures separately.

Why 3(38) fees usually run higher than 3(21) fees

The single most important fee distinction for many sponsors is 3(21) versus 3(38).

That extra discretion is why 3(38) service often costs more. The advisor is not just making recommendations; they are standing behind a delegated fiduciary role and an ongoing monitoring process.

The public advisor directory on PlanProvider.Pro reinforces how the market talks about those scopes. As of June 27, 2026, there were 638 published advisor profiles in the directory. Among them, 509 listed 3(21) service lines and 157 listed 3(38) service lines. Additional common service labels included plan design (91 profiles), participant advice (78), and compliance (46). That is directory profile data rather than a raw Schedule C market-share report, but it is still a useful reality check: sponsors are often evaluating a bundle of advisory scopes, not one simple asset-based quote.

Why small-plan advisor fees often look high in basis points

If your plan is small, basis points can be misleading because fixed annual minimums dominate the math. Suppose a sponsor has a $300,000 plan and receives a 0.50% quote with a $3,000 annual minimum. On paper, 50 bps would only equal $1,500. In practice, the minimum makes the advisor layer a full 1.00% of plan assets until the plan grows.

That does not automatically make the fee unreasonable. Small plans usually need the same core governance work as larger plans: investment oversight, committee support, participant education, vendor coordination, and annual fee review. The difference is that the asset base is smaller, so those fixed costs consume a larger percentage of assets.

This is exactly why the public benchmark data is useful. A sponsor with fewer than 100 participants should not benchmark against the national 0.39% median alone. They should start with the small-plan 401(k) median of 1.51%, then ask how much of that stack is advisor cost versus recordkeeping, investment, and other vendor expense. If you are comparing that small-plan quote to an advisor-only Form 5500 average, make the sample-frame adjustment mentally: the advisor-only average is mostly reflecting 100-plus participant plans that filed a full Form 5500, and those larger plans usually price lower than the small-plan market.

How to tell when an advisor quote is actually high

A fee becomes meaningfully harder to defend when one or more of these things are true:

As a practical example, a mid-sized 401(k) with 100 to 499 participants has a current all-in median fee of 0.32%. A standalone advisor fee near or above that level is not impossible, but it should trigger a deeper review because the advisor layer alone would be matching or exceeding what the median plan spends across the full fee stack.

For larger plans, the scrutiny should be even tighter. Once you get into the 1,000-plus or 5,000-plus participant range, institutional pricing is usually strong enough that plan sponsors should expect documented reasons for every incremental basis point.

How to benchmark your own advisor fee the right way

  1. Start with total plan cost. Use the live 401(k) fee benchmark and compare your plan to the right participant band, not just the national median.

  2. Pull the advisor scope in writing. Confirm whether the relationship is 3(21), 3(38), participant advice, plan design support, compliance support, or some combination.

  3. Review the latest Form 5500 and Schedule C. Match the advisor work to the disclosed service categories and compensation lines where available.

  4. Check who is paying. Sponsor-paid and plan-paid advisor arrangements can look very different in participant-level cost.

  5. Benchmark the ecosystem, not just the advisor. Compare the advisor next to recordkeeping, investment, and administrative costs, especially if the quote is part of a bundled arrangement.

  6. Revisit fees as the plan grows. Larger plans should usually pick up pricing breakpoints or renegotiated terms over time.

If you want to inspect real plan filings while you do this, the easiest next step is the Form 5500 database. If you are actively shopping the market, you can compare firms in the 401(k) advisor directory or review the largest retirement plan advisors to see how firms position their services.

Bottom line

The best current public benchmark for 401(k) fees is 0.39% all-in for the median U.S. 401(k) plan in 2024, but that number only becomes useful when you layer in plan size and service scope. Small plans naturally run higher. Large plans should be much tighter. And advisor fees should always be interpreted through the lens of what the advisor is actually doing, especially when the distinction is really about 3(21) advice versus 3(38) discretion.

If you want a second benchmark before making a change, pair this page with our broader 401(k) fee benchmarking guide and how to hire a retirement plan advisor. That combination gives you the numbers, the fiduciary framework, and the market context to decide whether a quote is normal, high, or worth renegotiating.