ERISA EBP Audit Specialists — DC, MD & VA

401(k) & Employee Benefit Plan Audit — ERISA Compliance for DC, Maryland & Virginia Employers

An employee benefit plan audit is an independent CPA audit of a 401(k), 403(b) or pension plan's financial statements, filed with Form 5500. ERISA generally requires one when a plan has 100 or more participants with account balances at the start of the plan year; the 80–120 participant rule lets some plans keep filing as small plans.

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When is a 401(k) plan required to have an annual CPA audit?

A 401(k) or other ERISA-covered plan is required to have an annual independent CPA audit when it has 100 or more participants with account balances at the beginning of the plan year. The audited financial statements are attached to Form 5500 filed with the DOL. Missing it can trigger IRS penalties of $250 per day, up to $150,000, plus Department of Labor penalties.

Limited Scope Audit: A limited scope audit (ERISA Section 103(a)(3)(C) audit) allows the CPA to exclude investment information certified by a qualified financial institution from testing, significantly reducing audit scope and cost. Most 401(k) plans qualify for limited scope because investments are held by qualifying trustees like Fidelity, Vanguard, or Empower.

ERISA: ERISA (Employee Retirement Income Security Act of 1974) is the federal law governing employer-sponsored retirement and welfare benefit plans, including 401(k), pension, and health plans. ERISA mandates annual audits for large plans and requires Form 5500 filings with the Department of Labor.

Employee Benefit Plan Audit Types by Plan Size

Fees depend on plan size, participant count, and records quality. We are transparent and charge fair fees quoted upfront after a short call.

Feature	Plan Size	Audit Type
Under 200 participants	Limited scope	Contributions, distributions, participant data
200–500 participants	Limited scope	Higher transaction volume, loans, eligibility testing
500–1,000 participants	Limited scope	Larger participant samples, multiple payroll locations
Any size (full scope)	Full scope	Investment testing not certified by a qualified institution
First-year audit (any size)	Limited or full scope	Additional opening-balance procedures

Employee Benefit Plan Audit Services

Full ERISA compliance support — from limited scope 401(k) audits to DOL representation and plan document review.

Limited Scope EBP Audit

The most common form of 401(k) plan audit. The plan trustee certifies the completeness and accuracy of investment information — reducing CPA audit procedures. We perform limited scope audits under AU-C 703, issuing the required ERISA Section 103(a)(3)(C) audit report for attachment to Form 5500.

Full Scope EBP Audit

Required when trustee certification is not available or when the DOL requires a full scope engagement. We perform a complete audit of all plan transactions and financial statements under AICPA SAS standards and DOL regulations, issuing an unqualified audit opinion on the plan's financial statements.

Form 5500 Filing Support

Form 5500 must be filed by the last day of the 7th month after plan year end (July 31 for calendar year plans) or October 15 with extension. We coordinate the audit deliverable with your Form 5500 preparer, provide the required audit report attachment, and help ensure timely filing to avoid DOL late-filing penalties.

DOL Audit Representation

If your plan receives a DOL investigation letter or is selected for a compliance audit, we represent you during the process. We review your plan's compliance, identify potential issues, and work with plan counsel to respond to DOL inquiries, correcting deficiencies through the VFCP (Voluntary Fiduciary Correction Program) where applicable.

Plan Document & Compliance Review

As part of our EBP audit, we review plan documents for compliance with current law, identify operational failures (loans not meeting plan requirements, late contributions, missing participant notices), and recommend corrections through IRS EPCRS or DOL VFCP before they become findings.

80–120 Participant Rule Analysis

Plans with between 80 and 120 participants with account balances at plan year start may elect to file as a small plan (no audit required) if they were a small plan the prior year. We analyze your plan's participant count and provide clear guidance on whether the audit requirement applies and how to document the participant count.

Serving Employers Across DC, Maryland & Virginia

From DC-area associations and nonprofits to Virginia and Maryland businesses, we serve employers across all industries with 401(k) plans requiring ERISA audits.

Washington DC

Associations, nonprofits, law firms, and professional services firms with 100+ plan participants

Northern Virginia (Fairfax, Loudoun, Arlington)

Tech companies, defense contractors, and healthcare systems with large participant counts

Montgomery County, MD

Healthcare, biotech, and professional services employers in Bethesda and Rockville

Baltimore Metro, MD

Financial services, healthcare systems, universities, and manufacturing companies

Richmond & Hampton Roads, VA

Financial institutions, healthcare systems, state government contractors

Across the DMV Region

Any employer with a 401(k), 403(b), pension, profit-sharing, or ESOP with 100+ participants

The DC metro area has thousands of employers with 100+ participant benefit plans across government contractors, nonprofits, law firms, healthcare systems, and technology companies. Many don't realize their plan requires an annual CPA audit — until the DOL sends a penalty notice. Your Virtual CPA performs the audit and helps you plan around the Form 5500 deadline.

Related Services

Nonprofit Audit (Single Audit)

Federal compliance audits for nonprofits.

Small Business Audit

Audits for bank loans, SBA, and investors.

Government Contractor Audit

DCAA compliance for federal contractors.

Attestation Services

AUPs, reviews, and SSAE 18 engagements.

Virtual CFO Services

Ongoing financial oversight for growing businesses.

Free consultation

Talk to an EBP audit specialist.

Employee Benefit Plan Audit FAQs

Common questions from HR teams and CFOs about ERISA audit requirements, Form 5500, and DOL compliance.

When a plan has 100 or more participants with account balances at the beginning of the plan year. The audit report attaches to Form 5500 filed with the DOL. Missing it can trigger IRS penalties of $250 per day, up to $150,000, plus Department of Labor penalties.

Plans with 80–120 participants at plan year start may continue filing as a small plan (no audit required) if they filed as small in the prior year. Once a plan exceeds 120 participants, the audit is required in all future years.

Late remittance of employee contributions; participant loan violations (exceeding 50% of vested balance or 5-year term); missing participant disclosures (SPD, fee disclosures); incorrect vesting calculations; and improper distribution processing.

Fees depend on plan size, participant count, audit type (limited vs. full scope), whether it is a first-year audit, and the quality of your records. We are transparent and charge fair fees quoted upfront after a short call.

In a limited scope audit, the trustee (Fidelity, Vanguard, Principal) certifies investment information, reducing the CPA's investment testing. Full scope audits test all plan assets. Limited scope is permitted under ERISA Section 103(a)(3)(C) and accepted by the DOL for most plans.

DOL penalties of $250/day up to $150,000/year. The DOL's DFVC Program allows late filers to pay reduced penalties. Contact us immediately if your deadline has passed.

Plan document and amendments; trust agreement; prior year Form 5500; trustee investment statements; participant loan detail; contribution and distribution schedules; payroll records; and plan administrator records (enrollment, beneficiary, loan approvals).

Timing depends on the size of the plan, plan features such as participant loans, how quickly your recordkeeper and TPA provide documents, and your Form 5500 deadline. We agree on a schedule with you before fieldwork starts and plan backward from that deadline.

Is Your 401(k) Plan Due for an Audit?

Don't wait for a DOL penalty notice. If your plan has 100 or more participants with account balances, the audit is generally required. Our team delivers ERISA-compliant employee benefit plan audits with clear pricing and expert DOL coordination.