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Monday, October 5, 2026

DOL Updates Auditor Independence Rules for Employee Benefits Plans - SHRM

The U.S. Department of Labor's (DOL's) Employee Benefits Security Administration issued Interpretive Bulletin (IB) 2022-01 on Sept. 6, updating its guidance on the independence requirement for accountants who audit employee benefits plans under the Employee Retirement Income Security Act (ERISA). IB 2022-01 took effect immediately on its publication in the Federal Register.

The DOL had issued an IB in 1975 that set forth guidelines for determining when a qualified public accountant is independent for purposes of auditing and rendering an opinion on the financial statements required in a benefits plan's Form 5500 annual filing. IB 2022-01 revises and restates the earlier guidance to remove certain outdated and unnecessarily restrictive provisions and to reorganize other provisions for clarity, the DOL said.

Ali Khawar, acting assistant secretary of labor for employee benefits security, said the DOL wanted to ensure its guidance on benefits plan audits "continues to foster proper auditor independence while also removing outdated and unnecessary barriers to plans accessing highly qualified auditors and audit firms."

Audit Requirements

Under ERISA, plan administrators—subject to certain exceptions—are required to retain an "independent qualified public accountant" to conduct an annual examination of the plan's financial statements in accordance with generally accepted auditing standards.

The accountant also must render an opinion as to whether the financial statements are...



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