For employee benefit plan audit practices
The plans that will need their first audit, before they choose an auditor.
Each year about 2,000 retirement plans cross the 120-participant line and need an independent qualified public accountant for the first time. We find them in the Department of Labor's Form 5500 filings and list them by state, with participant trend, assets and filing deadlines.
Download a free sample for your state
PDF: five forecast plans with sponsor names, the state count and current auditor market shares. No sign-up. Other states: hello@firstauditradar.comForecast list · plan year 2026 first auditsExcerpt, sponsors masked
| Sponsor | Participants w/ balance | Net assets | Audited 5500 due |
|---|---|---|---|
| Manufacturer Mokena, IL · 401(k) | 90 → 174a b | $8.26m | 31 Jul 2027c |
| Business services El Segundo, CA · 401(k) | 116 → 128a b | $5.37m | 31 Jul 2027c |
| Transportation company Jacksonville, FL · 401(k) | 96 → 128a b | $0.64m | 31 Jul 2027c |
| Hospitality business Los Angeles, CA · 401(k) | 99 → 123a b | $1.86m | 31 Jul 2027c |
| Recreation business Burr Ridge, IL · 401(k) | 95 → 138a b | $0.47m | 31 Jul 2027c |
2,085plans on the current forecast list
81%filed an audited return the next year in our 2023 back-test
5,627plans at 100-120 participants on the watch list
$20,000median audit fee reported on last year's audited filings
Sound familiar?
First audits rarely reach you first
The recordkeeper already picked someone
By the time a sponsor calls you, their recordkeeper or adviser has often recommended another firm.
You hear about the plan in July
The sponsor discovers the audit requirement when the 5500 is due, and takes whoever has capacity that week.
The data is free, the work is not
Three years of EFAST2 files, the 80-120 rule and plan matching take a staff member several days, every time.
How practices use it
A short list of plans that are about to need you
Most first-time audit clients come through recordkeepers, advisers or referrals, often after the sponsor has already asked around. The forecast list lets you start that conversation earlier.
Prospecting
Reach sponsors first
Contact plan sponsors in your area during their first audited plan year, before engagement letters for the 2027 filing season go out.
Instead of waiting for the call in July
Referral partners
Talk to recordkeepers and TPAs
Bring a concrete list to the advisers and recordkeepers who serve these plans. They need an auditor to recommend.
Instead of a general "we do 401(k) audits" pitch
Capacity planning
See next year's demand
The watch list shows the plans at 100-120 participants that are likely to follow a year later, by state and industry.
Instead of guessing how many seniors to hire for busy season
Method
Built on the audit requirement itself
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 PY2023 only participants with account balances countThe 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)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 2,166 plans the rule flagged for plan year 2023
- 81%
- filed an audited Form 5500 for 2024 (1,752 plans)
- 5%
- filed the short form again
- 14%
- terminated, merged, changed EIN or filed late
We rerun the test each year and publish the result on this page. Every row in the list shows the underlying counts, so you can judge each plan yourself.
Timing
Where a plan on the list is today
31 Dec 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
Most sponsors engage an auditor for fieldwork after the plan year closes.
31 Jul 2027
Audited 5500 due
Or 15 Oct 2027 with a Form 5558 extension, for calendar-year plans.
What subscribers receive
One row per plan, delivered monthly as CSV and PDF
Plan and sponsor
- Sponsor name and DBA
- EIN and plan number
- Plan name and type
- City, state, ZIP
- Industry (NAICS)
Why it is on the list
- Participants with balances, start and end of 2025
- Net assets at year-end
- Plan year end
- Date the 5500-SF was received
Deadlines
- First audited plan year
- Audited Form 5500 due date
- Due date with Form 5558
Market view
- Watch list at 100-120 participants
- New large plans filed with an audit
- Auditor market shares by state
Company-level data only: no names of individuals, no phone numbers.
Coverage
Forecast and watch list by state
Counts from the current list. Founding customers can choose a single state; nationwide covers all 50 states and DC.
Pricing
One new audit client pays for many years of the list
A first-year 401(k) audit is a recurring engagement. Set your own assumptions below; the result is an illustration, not a promise.
New audit clients1.1
Annual fees, recurring$14,200
Versus the founding price49×
91 plans × 30% × 4% = 1.1 clients × $13,000
Founding price $290 for one state, $990 nationwide. Typical fee for a 401(k) plan with 100-300 participants is around $13,000 per year.
Founding prices hold for the first 25 firms and are guaranteed for the first year. Invoiced in USD; business customers only.
One state
$290 per year
Regular price $490
- Forecast list and watch list for one state (or a region of smaller states)
- Current auditor market shares
- Monthly updates through the filing season, CSV and PDF
Nationwide
$990 per year
Regular price $1,490
- All states and DC
- Everything in the state plan
- National market view and new large plans
Questions
What audit partners ask us
Where does the data come from?
From the public Form 5500 and 5500-SF datasets the Department of Labor (EBSA) publishes through EFAST2, refreshed monthly. We match filings across plan years by EIN and plan number, remove duplicates and final filings, and apply the participant rules.
Is contacting these sponsors consistent with the AICPA Code?
The Code permits advertising and solicitation that is not false, misleading or deceptive (ET 1.600.001). The list is company-level public data; how and whom you contact remains your decision and responsibility.
Does the list contain personal data?
No. It contains the plan sponsor, EIN, plan name and number, city, industry and plan figures. Names of signers and preparers are removed and phone numbers are not included.
How is this different from searching the 5500 data myself?
You can do that. It takes three plan years of files, matching by EIN and plan number, the 80-120 rule and the switch to participants with account balances. We do it every month and add deadlines and a market view.
Why do 19% of plans not get audited?
In the back-test they were terminated, merged into another plan, changed EIN, filed late, or stayed on the short form. The participant counts on each row help you spot borderline cases.
Can I cancel?
The subscription runs 12 months. You can switch off renewal at any time before the renewal date.
Who runs First Audit Radar
An independent data service
First Audit Radar is run by Christoph Ploner from Eisenstadt, Austria. It is not affiliated with the Department of Labor, the AICPA or any audit firm, and it does not sell plan data to plan sponsors or recordkeepers.
Questions about the method or a specific state: hello@firstauditradar.com
2,085 plans need a first auditor for plan year 2026.
See the ones in your state today. The sample is free and takes one click.