401(k) & Employee Benefit Plan Audit — ERISA Compliance for DC, Maryland & Virginia Employers
Under ERISA, 401(k) plans, pension plans, and other employee benefit plans with 100 or more eligible participants at the start of the plan year must have an annual audit by an independent CPA and file the audit report with Form 5500 with the Department of Labor. Failure to file results in penalties of $250 per day — up to $150,000 per year. Your Virtual CPA performs ERISA-required employee benefit plan audits for employers across DC, Maryland, and Virginia, including both limited scope and full scope audits.
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 eligible participants at the beginning of the plan year. The audited financial statements are attached to Form 5500 filed with the DOL. Missing this requirement results in penalties of $250 per day up to $150,000 per year.
- 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 Cost Estimates
Typical cost ranges for EBP audits in DC, Maryland, and Virginia (2026)
| Feature | Plan Size | Audit Type | Estimated Cost |
|---|---|---|---|
| Under 200 participants | Limited scope | $5,000–$8,000 | |
| 200–500 participants | Limited scope | $7,000–$12,000 | |
| 500–1,000 participants | Limited scope | $10,000–$18,000 | |
| Any size (full scope) | Full scope | $15,000–$30,000+ | |
| First-year audit (any size) | Add for opening balances | +$2,000–$5,000 |
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 eligible participants 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 eligibility determination.
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 helps you stay compliant and avoid costly penalties.
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Book a 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.
Is Your 401(k) Plan Due for an Audit?
Don't wait for a DOL penalty notice. If your plan has 100 or more eligible participants, the audit is required. Our team delivers ERISA-compliant employee benefit plan audits with fixed pricing and expert DOL coordination.
Serving employers in Washington DC, Virginia, Maryland, and remotely nationwide.