INSIGHT

Year-End Checklist: Preparing Your Retirement Plan Records for Audit Season

Ryan Davis • September 16, 2026

Services: Employee Benefit Plan Audit

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December brings a familiar scramble for plan sponsors. Payroll closes out, benefits enrollment wraps up, and somewhere on the list sits a task that often gets pushed to January: getting your retirement plan records ready for the annual audit. Generally, if your 401(k) plan has 100 or more participants with account balances at the beginning of the year, 401(k) audit requirements may apply, and the records you gather now will shape how smoothly the process goes come spring.

Key Steps to Include in Your Checklist 

This article walks through the key items to gather, verify, and organize before your auditor’s first request lands in your inbox. 

1. Start with Participant Data 

Auditors trace almost every test back to participant records, so accuracy here sets the tone for the entire engagement. Pull a current census that includes hire dates, birth dates, and termination dates as well as compensation information. Cross-check this data against your payroll system, since mismatches between payroll and recordkeeper files cause more audit delays than almost any other issue. 

Review your retirement plan internal controls for eligibility tracking too. Confirm that employees who crossed an age or service threshold entered the plan on time, and flag anyone who should have been offered enrollment but wasn’t. Catching these gaps before the audit gives you room to correct them rather than explain them. 

2. Reconcile Contributions & Deposits 

Your auditor will test whether employee deferrals reached the plan’s trust within a reasonable timeframe after each payroll run. Gather your deposit dates alongside payroll withholding dates for the full year and calculate the lag between the two. The Department of Labor treats late deposits as a fiduciary matter, so identifying timing issues now lets you address them before an examiner does. 

Match employer contributions, whether matching, profit sharing, or safe harbor, against your plan document’s formula. A single miscalculated match can become a 401(k) compliance issue requiring a corrective contribution, and finding that error in December beats finding it in the following year.

3. Gather Distribution & Loan Documentation 

Every distribution processed during the year needs a paper trail:  

• the participant’s request 
• spousal consent where required 
• tax withholding calculations 
• proof of payment 

Loans carry their own documentation burden, including promissory notes, repayment schedules, and evidence that payments were deducted correctly from payroll.  Pay close attention to participants who took hardship withdrawals. Recent rule changes have loosened some documentation requirements, but your plan document still governs what you must keep on file. Pull these records into one folder now so you aren’t chasing down signatures during the audit itself. 

4. Confirm Your Plan Document Is Current 

Plan amendments pile up quietly over a year, and auditors will ask whether your plan operated according to its written terms. Review every amendment executed during the plan year, including any required by law, and confirm each one was adopted by the deadline. If your plan uses a pre-approved document, check that your provider issued any required restatement on schedule. 

This is also the moment to review your Summary Plan Description and confirm it reflects current plan provisions. A stale SPD creates confusion for participants and questions from auditors alike. 

5. Request Your Service Provider Reports 

Most sponsors rely on a recordkeeper or third-party administrator for day-to-day plan operations, which means your auditor needs evidence that those providers maintained proper controls. Request the SOC 1 report from each service provider well before year-end, since these reports sometimes take weeks to arrive. Read through the complementary user entity controls section, because it lists the responsibilities your organization must fulfill for the provider’s controls to work as intended. 

6. Organize Investment & Fee Information 

Gather your trust statements, investment policy statement, and any fee benchmarking studies completed during the year. If your plan added or removed investment options, document the committee decision and the rationale behind it. Fee disclosures to participants should also be on hand, along with proof they went out on schedule. 

7. Build a Single Audit File 

Once you’ve gathered these pieces, consolidate them into one organized file, whether digital or physical, that your auditor can access from day one. A clean, complete file shortens fieldwork, reduces the number of follow-up requests, and gives your team more time to focus on year-end close instead of hunting for documents. 

Working with BPM 

A well-organized plan file makes audit season shorter and less disruptive, but pulling everything together takes planning and a clear sense of what matters most to reviewers. BPM’s Employee Benefit Plan Audit services work with sponsors throughout the year, not just during fieldwork, to keep plan records audit-ready and to flag issues before they grow into compliance problems. 

If your plan sponsors a 401(k), 403(b), pension, or ESOP and audit season is approaching, contact us to talk through your year-end checklist and what your team should prioritize before the audit begins.