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1Scan for outdated or missing drivers - takes under a minute2Repair Windows errors before they cause bigger problems3Fix the driver behind crashes, sound loss and screen glitchesFor the 2026 U.S. employee benefit plan (EBP) audit season, the most consequential issues are plan-specific audit execution, the new SECURE 2.0 paper-statement requirement, and the Department of Labor’s temporary enforcement policy for electronic disclosures. Plans generally need an audit when they have 100 or more participants for Form 5500 reporting, while some smaller pension plans also qualify under special conditions. Auditors and administrators should document the applicable rule, effective date, plan type, and evidence supporting each conclusion.
Which employee benefit plans need an audit in 2026?
The Department of Labor (DOL) generally requires an employee benefit plan with 100 or more participants to include an audit with its Form 5500 series annual return or report. Participant counting and filing status must be evaluated under the applicable reporting rules rather than assumed from a plan’s total headcount or payroll records.
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Some pension plans with fewer than 100 participants may also need an audit. DOL identifies investment arrangements, bonding requirements, and disclosure conditions as factors that can trigger the obligation. A small plan should therefore document why an audit is or is not required instead of relying solely on the number of participants.
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The plan auditor must be licensed or certified by a state regulatory authority. Experience with benefit plans matters because the engagement involves transactions, participant records, fiduciary processes, and regulatory requirements that do not arise in the same combination in an ordinary commercial audit. DOL has warned that deficient reports commonly result when auditors fail to test areas unique to employee benefit plans.
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What the filing deadline means for audit planning
The audit is part of the Form 5500 reporting process, so the engagement calendar should begin early enough to resolve data, valuation, contribution, and participant-account issues before the annual filing is assembled. A plan administrator should confirm the plan year, participant count, audit requirement, auditor credentials, engagement scope, and expected delivery dates in writing.
Core plan-specific testing areas
DOL’s administrator guidance identifies the following subjects for review. They are essential benefit-plan considerations, not a replacement for applicable auditing standards, the plan document, the engagement risk assessment, or the complete professional audit guide.
- Asset valuation: Determine whether covered assets are fairly valued and whether the valuation method is supported by appropriate records. Hard-to-value investments, valuation dates, and differences between recordkeeper data and custodial statements deserve particular attention.
- Plan obligations: Test whether obligations are properly stated and described. The work should reconcile liabilities and disclosures to the governing plan terms and available actuarial or administrative information.
- Timeliness of contributions: Examine whether employee deferrals, employer contributions, and other required deposits reached the plan within the applicable period. Late deposits can create correction, disclosure, and prohibited-transaction implications.
- Benefit payments: Verify that distributions, loans, withdrawals, and other benefit payments were made in accordance with the plan’s terms and participant elections.
- Participant accounts: When applicable, test whether individual account balances and activity are fairly stated. The auditor should understand how payroll, investment transactions, fees, forfeitures, and recordkeeper files flow into participant statements.
- Tax-status risks: Identify matters that could affect the plan’s tax qualification or other tax status. This may include operational failures, contribution-limit issues, eligibility errors, or transactions inconsistent with the written plan.
- ERISA-prohibited transactions: Consider whether prohibited transactions were identified and properly addressed, including transactions involving parties in interest or plan assets.
Evidence an administrator should prepare
A practical request list includes the current signed plan document and amendments, trust or custodial statements, investment valuation support, payroll and contribution files, remittance records, participant census data, distribution and loan reports, forfeiture activity, fee invoices, operational corrections, and prior-year audit findings. Keeping a reconciliation that explains differences between payroll, recordkeeper, trustee, and general-ledger data can shorten fieldwork and expose errors before filing.
SECURE 2.0 paper pension benefit statements
SECURE 2.0 added a paper-format requirement to ERISA section 105(a)(2)(E). It applies for plan years beginning after December 31, 2025. The requirement is distinct from the ordinary electronic-disclosure rules and should be tracked by plan type and calendar year.
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| Plan type | Minimum paper statement frequency | Timing rule |
|---|---|---|
| Individual account plan, including a defined contribution arrangement | At least one pension benefit statement on paper in any calendar year | Applies for plan years beginning after December 31, 2025 |
| Defined benefit plan | Generally at least one paper pension benefit statement every three calendar years | Applies for plan years beginning after December 31, 2025 |
The paper requirement does not mean every statement must be mailed on paper. It establishes a minimum paper delivery frequency while other statements may continue to be delivered electronically when the applicable disclosure rules are satisfied. Administrators should maintain evidence of the paper delivery process, returned mail handling, address controls, and the statement content used.
What auditors should test
- Classify the plan correctly as an individual account or defined benefit plan.
- Confirm when the plan year beginning after December 31, 2025 starts.
- Inspect the communication calendar to verify that the required paper statement will be furnished within the relevant calendar-year or three-calendar-year interval.
- Test a sample of participant records for address accuracy, delivery status, returned mail, and documented follow-up.
- Reconcile the population receiving statements to the plan’s participant and beneficiary records.
DOL’s proposed electronic-disclosure rule and temporary enforcement policy
On May 12, 2026, DOL issued Field Assistance Bulletin 2026-02 describing a proposed electronic-delivery rule and a temporary enforcement policy. DOL had published a notice of proposed rulemaking on February 25, 2026 concerning amendments to electronic-disclosure safe harbors.
The legal status of these items matters:
| Item | Status in 2026 | What administrators should do |
|---|---|---|
| SECURE 2.0 paper-statement requirement | Statutory requirement effective for plan years beginning after December 31, 2025 | Build the required paper delivery into the plan’s compliance calendar |
| DOL electronic-disclosure amendments | Proposed rule; not a final regulation | Monitor the rulemaking and do not treat the proposal as final law |
| DOL temporary enforcement policy | Temporary enforcement discretion while final rules or other applicable administrative guidance are pending | Follow a good-faith, reasonable interpretation and preserve the basis for that interpretation |
DOL states that, pending a final regulation or other applicable guidance, it will not take enforcement action against administrators who comply in good faith with a reasonable interpretation of the relevant provisions. That is enforcement discretion, not a repeal, waiver, or postponement of the statutory paper requirement. A compliance file should identify the interpretation used, the communications delivered, the paper statements furnished, and the controls used to monitor further DOL guidance.
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Separating proposed options from current obligations
A proposed notice or disclosure option can inform planning, but it does not automatically authorize a new delivery method. Policies should label each process as required by statute, permitted under an existing safe harbor, proposed by DOL, or followed under the temporary enforcement policy. This labeling prevents a draft rule from being presented to participants or auditors as a final requirement.
2026 quarterly statement deadline for participant-directed plans
For calendar-year participant-directed defined contribution plans, DOL said the quarterly pension benefit statement for the quarter ended March 31, 2026 was due no later than May 15, 2026. This is a specific 2026 timing point, not a universal annual deadline for every employee benefit plan.
DOL’s bulletin refers to approximately 720,000 participant-directed defined contribution plans, citing the department’s January 2026 abstract of 2023 Form 5500 Annual Reports. The figure is a national plan count from that source and year; it is not an estimate of the number of plans that missed the deadline or a measure of audit deficiencies.
Controls for the quarterly statement process
- Set the quarter-end close date and identify the participant population covered by the statement rule.
- Extract account balances, contributions, investment activity, fees, and required explanatory information from the recordkeeping system.
- Reconcile the statement population and totals to payroll, trust, and recordkeeper reports.
- Review a sample of statements for required information, calculation accuracy, and participant-directed investment data.
- Document the delivery date, method, returned statements, and remediation of failed deliveries.
How the 2026 hot-topic agenda affects the audit engagement
The exact AICPA & CIMA resource titled “2026 EBP Audit Season Hot Topics” is dated June 8, 2026 and is available through member access. Its public description says it addresses current EBP hot topics, regulatory developments, changes to the EBP Audit Guide, and recent peer review checklist updates. The public description does not disclose the detailed revisions, so no specific change to the guide or checklist should be attributed to it without reviewing the member-only material.
That distinction is important for quality control. An engagement team can acknowledge that guide and peer-review updates are part of the 2026 professional agenda while still relying on the current authoritative auditing standards, plan terms, DOL requirements, and the complete edition of the applicable audit guide.
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Quality-review questions for engagement teams
- Does the planning memo identify the plan’s participant count, plan type, filing obligation, and significant service providers?
- Does the risk assessment address valuation, contributions, benefits, participant accounts, tax status, and prohibited transactions?
- Are electronic and paper disclosure controls tested separately?
- Are exceptions evaluated for correction, disclosure, and possible effect on the audit opinion?
- Does the workpaper state which requirements were effective in 2026 and which matters remain proposed or subject to temporary enforcement discretion?
- Have current DOL guidance and the current Audit Guide and peer-review materials been checked before report issuance?
Common 2026 mistakes and how to correct them
Treating the 100-participant threshold as the only test
A small pension plan may still require an audit because of investment, bonding, or disclosure conditions. Correct the mistake by documenting all applicable conditions and obtaining advice from a qualified plan professional when the filing status is uncertain.
Calling the enforcement policy a delay
The temporary policy does not erase the statutory requirement. Correct the wording in policies and participant communications, furnish paper statements as required, and retain evidence supporting any good-faith reasonable interpretation used for electronic delivery.
Using one calendar for every plan
The May 15, 2026 date applies to the quarterly statement for the quarter ended March 31, 2026 for calendar-year participant-directed defined contribution plans. Correct the mistake by mapping deadlines to the plan year, plan type, statement period, and participant population.
Relying on generic commercial-audit procedures
Benefit-plan engagements require testing tailored to plan assets, obligations, contributions, benefit payments, participant accounts, tax status, and prohibited transactions. Correct the gap by linking each significant risk to a procedure, evidence source, reviewer, and conclusion.
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A practical 2026 readiness checklist
- Confirm the plan year, participant count, audit requirement, and Form 5500 filing timetable.
- Verify that the auditor is licensed or certified by a state regulatory authority and has relevant benefit-plan experience.
- Collect governing documents, amendments, service-provider reports, valuation evidence, payroll files, contribution records, and participant transactions.
- Map the SECURE 2.0 paper-statement requirement to the plan type and effective plan year.
- Review electronic-disclosure procedures under current rules and document any reliance on DOL’s temporary enforcement policy.
- Test the May 15 quarterly-statement requirement where the plan is a calendar-year, participant-directed defined contribution plan.
- Evaluate exceptions for correction, participant notification, tax qualification, prohibited transactions, and financial-statement disclosure.
- Before signing, check current DOL guidance and the current professional audit and peer-review materials for changes issued after the engagement was planned.
What to monitor after the 2026 filing
The regulatory picture can change during the season. Administrators should monitor whether DOL finalizes, withdraws, or revises the proposed electronic-disclosure amendments and whether additional administrative guidance changes the temporary enforcement policy. Auditors should update risk assessments and workpapers when new guidance affects the period under audit or the representation made in the Form 5500 filing.
For professional development, AICPA’s January 2026 DAQP webcast addressed DOL updates, SECURE 2.0 and related regulations, accounting, reporting and auditing updates, and quality resources. That establishes a training focus, not a guarantee of a particular course schedule or enrollment availability.
The Bottom Line
The 2026 EBP audit season turns on disciplined plan-specific testing and precise treatment of SECURE 2.0. Build the paper-statement requirement into every affected plan’s calendar, treat DOL’s electronic-disclosure policy as temporary enforcement discretion rather than a legal delay, and document the evidence supporting the audit conclusion and Form 5500 filing.
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