First-audit deadlines for the plan year 2025 list

Plan year ends and deadline months of the flagged plans

Every flagged plan grouped by the end of its 2025 plan year, as reported on the short form, and split the way our home page counts. 2,002 of the 2,057 flagged plans show no audited return for an earlier year. 1,993 of them run on a calendar year, so their audited Form 5500 for plan year 2026 is due by Jul 31, 2027 (filing on Aug 2, 2027 is on time under the weekend note): 1,981 as their first audit, and 12 that already started 2025 above 120, so their first audit was probably due for 2025 and is overdue. The other 9 use a fiscal year, which moves both deadlines. The 55 plans returning to audit already had an audited return for an earlier year; they are shown separately. Dates follow the rule above; where a date falls on a Saturday, Sunday or federal holiday, the table shows the next business day, marked *.

A typical first audit, step by step

General steps only; the order and the work differ from plan to plan and from firm to firm.

1. The signal. The 2025 short form with 121 or more participants with balances reaches the DOL data (for these plans: received through Sep 24, 2026).
2. The first large-plan year runs. Plan year 2026 is the year to be audited. Sponsors often hear about the requirement from their recordkeeper or third-party administrator.
3. The sponsor engages an auditor. Usually before or soon after the plan year closes, with an engagement letter that sets the scope. Many first-year plans qualify for an ERISA section 103(a)(3)(C) audit when a qualified institution certifies the investment information.
4. Planning and opening balances. In a first audit the auditor also needs the balances at the start of the year and information about earlier years: plan document and amendments, recordkeeper and custodian reports, payroll and participant data.
5. Fieldwork after year-end. Testing of contributions, distributions, participant data and investments once the year-end reports are available.
6. Report and filing. The auditor's report is attached to the Form 5500 with Schedule H by Jul 31, 2027, or Oct 15, 2027 with Form 5558.

What such an engagement costs: we do not estimate fees here. Plans that pay their auditor from plan assets report the fee on Schedule H; medians by plan type, size and state are on plan audit fees by size and state, with the limits of that source.

What this means for an audit firm

For the plans on today's list the decision about an auditor usually falls between now and the extended deadline in 2027. An introduction that arrives while the sponsor is still choosing reads very differently from one that arrives after a referral settled the question. How audit firms win first-year audit clients covers who decides and how to follow up.

First Audit Radar lists these plans every month with both deadlines for every plan, the sponsor, EIN, company phone and business address, and a follow-up calendar for your team. It does not know whether a sponsor has already engaged an auditor or filed an extension, and it holds no personal contact data. Look first: free state sample · plans by state · prices.