Our data
Where the list comes from, and how well it worked last year
The list applies the audit requirement itself to the Department of Labor's public Form 5500 data: the large-plan threshold, the 80-120 rule and participants with account balances. Every number has a source and a date, and we publish how last year's list turned out.
Method
Built on the audit requirement itself
1
The requirement
A plan with 100 or more participants with account balances at the beginning of the plan year files as a large plan and attaches the report of an independent qualified public accountant.
29 CFR 2520.103-1 · since 2023 only participants with account balances count2
The 80-120 rule
A plan that filed as a small plan the year before may keep doing so while it has no more than 120 participants at the start of the year.
29 CFR 2520.103-1(d)3
The signal
A plan that filed Form 5500-SF for 2025 and reported 121 or more participants with balances at year-end starts 2026 above the threshold. Its 2026 plan year is generally its first audited year.
DOL Form 5500 datasets (EFAST2), updated monthlyBack-test
What happened to the 2,134 plans the rule flagged for plan year 2023
81%
filed an audited Form 5500 the next year (1,737 plans) · full track record
- 81%
- audited return the next year
- 5%
- filed the short form again
- 14%
- terminated, merged, changed EIN or filed late
Historical back-test, not a guarantee for future plan years. We rerun the test every year and publish the result here. Every row in the list shows the underlying counts, so you can judge each plan yourself.
Data at a glance
Three pages behind every number
Track record
What happened to last year's list
81% of the plans the rule flagged filed an audited return the next year. Method and limits on the page.
See the back-test → Data sourcesEvery field, its source and its update
Which Form 5500 dataset each column comes from, when we refresh it and the known gaps.
Open the field list → ComparedForm 5500 databases vs. this list
Databases show who already has an auditor. This list shows who is about to need one.
See the comparison →2,000+plans likely to need their first audit for plan year 2026
$2.9mmedian net plan assets of the plans on the list
5,627plans at 100-120 participants on the watch list
$12,900median reported audit fee for 401(k) plans with 100-199 participants, plan year 2024
Timing
Where a plan on the list is today
Dec 31, 2025
Plan year ends
The plan finishes 2025 with 121 or more participants with balances and files Form 5500-SF.
Now
On the forecast list
The filing reaches the DOL dataset. The plan is in its first audited year and appears on the list.
Early 2027
Auditor engaged
Many sponsors only start looking for an auditor after the plan year closes.
Jul 31, 2027
Audited 5500 due
Or Oct 15, 2027 with a Form 5558 extension, for calendar-year plans.
Coverage
More than 2,000 plans across 50 states and DC
Forecast plans by sponsor state. Select a state for its industries, cities, deadlines and the audit firms active there.
AK1ME11VT7NH12WA32ID10MT5ND8MN53IL87WI25MI49NY136RI8MA66OR30NV16WY2SD5IA23IN33OH50PA90NJ71CT11CA333UT36CO54NE8MO40KY14WV2VA54MD37DE15AZ39NM8KS12AR9TN26NC44SC26DC18OK11LA18MS10AL15GA61HI2TX158FL133
Plans per state: 5-9 10-24 25-49 50-99 100+
Most forecast plans
- California333
- Texas158
- New York136
- Florida133
- Pennsylvania90
- Illinois87
- New Jersey71
- Massachusetts66
- Georgia61
- Colorado54
Free state sample
See the plans in your state today.
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