Who is Not Eligible to Be a Custodian of an HSA?

Health Savings Accounts (HSAs) are a valuable tool for individuals to save for medical expenses while enjoying tax benefits. One important aspect of an HSA is the custodian, who manages the account on behalf of the account holder. While many individuals are eligible to be custodians of an HSA, there are certain restrictions in place regarding who can fulfill this role.

So, who is not eligible to be a custodian of an HSA? The following individuals are not allowed to serve as custodians:

  • Employers - An employer who sponsors an HSA-qualified high deductible health plan cannot act as the custodian of the HSA associated with that plan, as it could lead to conflicts of interest.
  • Health Insurance Providers - Similarly, health insurance companies that provide coverage under an HSA-qualified high deductible health plan are not eligible to be custodians.
  • Non-Financial Institutions - Entities that are not financial institutions, such as healthcare providers or non-profit organizations, are also not permitted to be custodians of an HSA.

It is important to ensure that the chosen custodian meets the regulatory requirements set forth by the IRS to avoid any complications or penalties associated with an HSA. By selecting an eligible custodian, HSA account holders can maximize the benefits of their accounts and ensure compliance with the law.


Understanding who cannot act as a custodian for a Health Savings Account (HSA) is essential for optimizing your healthcare savings strategy. Not all individuals or organizations qualify to serve in this role.

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