What it is
An ERISA defined contribution plan audit tests three groups of facts: that contributions were deposited timely and correctly, that participant data and benefit payments follow the plan document, and that investments are properly valued. The auditor must be an independent qualified public accountant and the audit is performed under AU-C, including AU-C 703.
The checklist covers acceptance and independence, plan document compliance, contributions and participant data, investments and fair value, loans and distributions, and the financial statements and Form 5500 tie-out. Plan management can elect an ERISA section 103(a)(3)(C) audit, formerly called a limited-scope audit, and legal points are for plan counsel.
When to use it
- Planning an audit of a 401(k) or other defined contribution plan filing as a large plan.
- First-year plan audits, where the plan sponsor is new to the process.
- Reviewing a plan audit file before the Form 5500 deadline.
What’s inside
- Independence, scope and the full audit versus ERISA 103(a)(3)(C) audit decision
- Plan document, testing, bond and prohibited transaction inquiries
- Deferral and match tests, late deposit evaluation and participant data
- Investments, fees and recordkeeper SOC 1 report
- Loans, distributions, financial statements and supplemental schedules
Standard cited
This template follows ERISA 103 / AU-C 703 / ASC 962. It is written in our own words, except for phrases the standard requires the document to contain, with [bracketed placeholders] for client details, amounts in USD and dates as MM/DD/YYYY. Check it against the current standard and your firm’s methodology before use.
Questions
What is a limited-scope audit?
Under ERISA section 103(a)(3)(C) plan management may elect to have the auditor exclude investment information that a qualified institution, such as a bank or insurance carrier, certifies as complete and accurate. AU-C 703 (SAS 136) calls this an ERISA section 103(a)(3)(C) audit rather than a limited-scope audit, sets preconditions that include written acknowledgments from management, and prescribes the report form.
Which late deposits are reported?
Employee deferrals not deposited as soon as they could reasonably be segregated, as set out in the DOL regulation (29 CFR 2510.3-102), are reported and, with lost earnings, may need correction. Evaluate each late deposit and report in the supplemental schedule and Form 5500 as required.
Does independence differ for plan audits?
The AICPA Code applies, and DOL has its own independence and qualification rules for the independent qualified public accountant. Check both before accepting nonattest services for the plan or sponsor.
Related templates
- Payroll Testing Workpaper
- IPE Testing Worksheet (Information Produced by the Entity)
- Management Representation Letter (AU-C 580)
Last updated 11/05/2026. All free templates.