First Audit Radar
Track record · back-test

What happened to last year's list

We apply the First Audit Radar rule to past filings and check what the plans did next. Of the 2,134 plans the rule flagged for plan year 2023, 1,737 (81%) filed an audited Form 5500 for plan year 2024. Those audited returns were signed by 620 different audit firms; no single firm signed more than 3.6%.

81%of the 2,134 flagged plans filed an audited return the next year
620different audit firms signed those audited returns
3.6%largest share held by a single firm (top ten together 23%)
14.5 monthsmedian time from the short-form filing that put a plan on the list to its audited return
Outcome

The 2,134 plans flagged for plan year 2023

Rule: Form 5500-SF for 2023, 121 or more participants with account balances at year-end, sponsor is an organisation, not a final filing. Checked against every filing for plan year 2024 received through 24 Sep 2026.

1,737
filed an audited Form 5500 (accountant's opinion on Schedule H) for 2024: 81.4%
109
filed the short form again: 5.1%
288
no matching 2024 filing yet: terminated, merged, changed EIN or plan number, or filing late: 13.5%
Who won them

No firm owns this market

The 1,737 audited returns were signed by 620 different audit firms (counted by the firm's EIN on Schedule H). The most active single firm signed 63 of them (3.6%); the ten most active together 23%. 393 firms signed exactly one, together 23% of all audited returns.

New auditor or the previous one

A new auditor, or the previous one?

For the plan year 2024 list (prior years covered by our data: plan year 2023), 8 of the 264 audited returns for 2025 (3%) came from plans that already had an audit on file for an earlier year; 3 (1.1%) were signed by the same firm as before. The other 99% were signed by a firm that had not audited the plan in the years we can see. For the plan year 2023 list the public files we use do not reach far enough back for this check.

Timing

About a year of lead time

89% of the flagged plans were visible in the public data by 31 October 2024. Their audited return followed a median 14.5 months after the short-form filing (middle half 12 to 16 months): 64% arrived in October 2025, the extended deadline, and 4% by 31 July. Auditors are usually engaged in between, which is the window the list is for.

Examples, masked

Six plans from the 2023 list

Industry, state and size only. Participants with account balances at the start and end of 2023; month the short form reached the public data; month the audited return for 2024 arrived.

IndustryStateParticipants 2023On the list sinceAudited return filedMonths
Professional servicesTexas93 → 125Oct 2024Sep 202511
ConstructionVirginia115 → 128Jan 2025Dec 202511
ManufacturingWisconsin102 → 133Aug 2024Feb 202618
Health careOklahoma88 → 143Sep 2024Oct 202512
TransportationNew York108 → 164Oct 2024Oct 202512
Other servicesCalifornia82 → 326Jun 2024Oct 202516
In progress

The list for plan year 2024: audited returns for 2025 are still arriving

The rule flagged 2,393 plans for plan year 2024. Their audited returns were due by 31 July 2026, or 15 October 2026 with an extension; most sponsors file close to the extended deadline, so many have not reached the public data yet. Through 24 Sep 2026, 264 have arrived, signed by 138 different audit firms; the most active single firm holds 9.1% of them. This page is updated with every monthly data run.

By state

Plan year 2023 list: what happened, state by state

States with at least 10 flagged plans; the rest are combined. Audit firms = different firms that signed the audited returns in that state.

StateFlagged for 2023Audited for 2024ShareAudit firms
California34026879%132
New York14712182%79
Texas14512183%81
Florida1139180%61
Illinois997778%43
Pennsylvania897584%51
Virginia867081%44
New Jersey705984%50
Ohio705883%36
Massachusetts675684%33
Michigan584883%34
North Carolina584883%39
Colorado574375%30
Minnesota554073%22
Wisconsin544583%24
Georgia513874%28
Arizona483981%23
Washington453680%25
Maryland383387%26
Oregon373286%23
Indiana343088%20
Utah322784%22
Missouri312890%21
District of Columbia282486%22
Connecticut262388%18
Tennessee252288%17
Alabama221673%11
Kentucky2222100%17
South Carolina171588%14
Iowa151387%10
Louisiana151280%12
Nevada12975%9
Arkansas10880%6
Idaho10990%7
Kansas10770%6
Maine1010100%7
New Hampshire10770%5
14 smaller states695275%-
Method and limits

How we count, and what this does not show

Source: U.S. Department of Labor, Form 5500 public datasets (EFAST2), plan years 2023 and 2024, files as published through 24 Sep 2026. A plan counts as audited when the same EIN and plan number filed a large-plan Form 5500 for 2024 with an accountant's opinion on Schedule H. Audit firms are counted by the firm EIN on Schedule H (by name if no EIN is given).

Limits: matching by EIN and plan number counts a plan as a miss when the sponsor changed its EIN, merged the plan or renumbered it, so the true share is probably a little higher. Late filers are counted as misses until their filing appears. This is a back-test of the rule on past data, not a record of what our subscribers won and not a guarantee for future plan years. The list we sell today applies the same rule to plan year 2025. No plan, sponsor or audit firm is named on this page.

See the plans flagged for plan year 2025: free state sample · plans by state · prices, with a 30-day money-back guarantee.