We are rapidly approaching the first due date for 401(k) plan audits. Just as a reminder: for calendar year plans—those that run January to December—the Form 5500 filing deadline is the end of July. (If your plan runs on a different fiscal year, you’ll need to adjust accordingly.) You can request an extension until October 15, but the original due date is the end of July. That means your audit is also due at the end of July, since the audit report must be filed with Form 5500 to complete the process.
To help ensure your audit is completed on time, here are some key actions to take:
Discuss the Status and Timing with Your Auditor
Early in the engagement—during your kickoff, planning, or scheduling meeting—you should discuss the audit timeline with your auditor. Ask about their availability, any upcoming PTO, and any blackout dates. As auditors, we also try to understand when clients are processing payroll to avoid conflicting due dates.
Identify when the auditor will need key documents and when you expect to provide them. If milestone deadlines are missed, talk with your auditor immediately to get back on track. Keep in mind that your audit is likely not the only one your auditor is working on—so don’t expect them to catch up last minute.
Respond Quickly to Issues
If your auditor encounters issues during the audit, work with them to resolve problems promptly. When they request documentation, respond right away. If you don’t have a specific document, ask the auditor what acceptable alternatives might be. For example, if you’re missing an I-9, a W-4 or medical form might work, but only if your auditor agrees.
Sometimes clients hesitate to provide certain documents like bank statements. If privacy is a concern, redact unrelated information or provide only the relevant snippet that proves funding. But don’t leave it up to guesswork—always ask if your substitute is acceptable. Otherwise, you risk receiving an unfavorable audit opinion or a delay in completion of your audit.
Stay Organized
One of the biggest ways to keep your audit on schedule is to organize your documentation. Don’t dump everything into a single, unorganized PDF. Instead, group documents logically—e.g., all I-9s alphabetically, or everything related to one participant in a single packet.
If you use paper documents, scan both sides and check image quality before sending. We’ve seen important information like hire dates get missed because only the front of a form was scanned. Also, double-check that files are labeled and named correctly.
Clarify Rehires and Alternatives
If someone in the audit sample is a rehire or has multiple hire dates, ask the auditor what documentation is needed. They may want both hire dates. This kind of back-and-forth can create delays, so address it upfront.
Also remember: while we often request I-9s because they contain both birth and hire dates, alternative documents like offer letters or passports may also be acceptable. When in doubt, ask.
Use Secure File Transfer Methods
Submit documents using whatever secure method your auditor requests—Smartsheet, HubSync, or another secure portal. Do not email sensitive data unless you use a secure tool like SafeSend. Avoid sending demographic or payroll data via unencrypted email.
Communicate and Ask Questions
If you have questions or run into issues, schedule a meeting with your auditor. You may need to research discrepancies—for example, if timecards don’t align with payroll due to overtime being paid in arrears.
Coordinate with Service Providers
If part of the required documentation comes from a service provider, you may need to intervene. Remember, they work for you—not your auditor. Be prepared to follow up with payroll providers, recordkeepers, TPAs, or banks to get what’s needed. This is especially true if you don’t have a dedicated representative.
After fieldwork is done, if the audit identifies changes to the Form 5500, the service provider must update the form and return it to the auditor. We can’t finalize the audit report until we see a substantially complete 5500. Delays here—especially from service providers with long turnaround times—can hold everything up.
Sometimes we wait weeks or months for a revised 5500. If that happens, the client—not the auditor—has the leverage to escalate.
Prepare to Finalize the Audit
At the end of the audit, a management representation letter must be signed—typically by the plan trustee or administrator. This legal document affirms that you’ve provided accurate, complete information. It must be printed on company letterhead and signed (manually or electronically). Ensure the right people are available to sign it when the time comes.
You may also have to make a final payment to your audit firm. Check your firm’s policy—if your AP department only cuts checks monthly, that could cause a delay.
File on Time
Once the audit is finalized, the auditor will give you a full packet: the opinion letter, financials, disclosures, and supplemental schedules. You will file this packet with Form 5500 through your service provider’s system. Auditors cannot file it for you.
Keep in mind: as the deadline nears, the Department of Labor’s EFAST filing system may experience high traffic. If you’re filing at the last minute, expect potential delays.
Final Thoughts
Communication is key. Check in regularly with your auditor and service providers to keep things moving. A smooth and timely 401(k) audit requires coordination, preparation, and early action. If you’re aiming to meet the July deadline without requesting an extension, now is the time to act.
For more information on how our 401(k) audit team can help, request a free consultation below to discuss your unique 401(k) audit needs.
