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Employer or union prepaid legal plans are welfare plans
Summary DOL stated that prepaid legal service plans established or maintained by an employer or employee organization fall within ERISA’s welfare-plan definition and are subject to Title I parts 1 and 4. The letter gives a general interpretation for plans with those sponsorship facts.
Document
Federal opinion letter
Agency
U.S. Department of Labor, Employee Benefits Security Administration (EBSA)
Document number
P/OPINION 75-02
Date issued
February 14, 1975
Status
Unknown
EBSA's index does not mark withdrawn or superseded opinions; still posted on dol.gov as of 2026-10-26.
Status last verified October 26, 2026
Topics
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About this page: The full text below is the official document from U.S. Department of Labor, Employee Benefits Security Administration (EBSA). Ezel adds the plain-English summary and tracks the document's status. The official source linked on this page is authoritative for any reliance.
P/OPINION 75-02
3(1)
February 14, 1975
Dear :
Prepaid Legal service plans which are established or
maintained by an employer, or by an employee organization
or by both, fall under the definition of “welfare plans”
in section 3(1) of the Employee Retirement Income Security
Act of 1974 (the Act). Welfare plans are subject to the
requirements of Parts 1 and 4 of the Act.
The Department of Labor has published no regulations or
guidelines which solely concern prepaid legal service
plans.
Sincerely,
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