DOL Audit Requirements: A Critical Reminder for Retirement Plan Sponsors
4/7/2025 - By Camille Henry
For all employee benefit or retirement plan sponsors, it’s important to stay informed about regulatory changes regarding ERISA audit requirements.
Companies that sponsor retirement plans, such as a 401(k) plan, with 100 or more participants at the beginning of the year are classified as “large plans.” Large plan sponsors must submit an audit report with their annual Form 5500 filings.
Starting in 2023, the Department of Labor (DOL) introduced some relief through the 80–120 rule. This rule states that if a plan was considered a “small plan” filer in the previous year, it may continue until the participant count exceeds 120.
Effective for plan years 2023 and beyond, the DOL counts eligible employees with a balance in the plan as well as terminated employees who still have balances, as participants.
The deadline to file Form 5500 and the audit report conducted by an independent CPA firm is July 31, with an extension available until October 15.
If you have questions about your plan’s audit requirements or any other concerns regarding your employee benefit plan, reach out to Audit Supervisor Camille Henry.
For more details, refer to the regulatory guidance: Subpart C, § 2520.103-1(d) in the eCFR Rules and Regulations for Reporting and Disclosure. For more information on the types of ERISA retirement plans: Types of Retirement Plans | U.S. Department of Labor.
About the Author | Camille Henry
Camille is a supervisor in the Audit & Assurance Services practice of Saltmarsh, Cleaveland & Gund. She joined the firm in 2013 and has over 15 years of experience working in the financial institutions industry. Camille is also a part of the firm’s Financial Institution Advisory Group, with experience providing audit services to financial institutions, as well as specialized experience with employee benefit plan audits.
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