For Plan Sponsors
The 401(k) Fiduciary Checklist for Employers
Sponsoring a retirement plan is one of the most consequential fiduciary roles an employer holds. Use this checklist to review your investment menu oversight, fee benchmarking, and documentation processes — and reduce fiduciary burden in the process.
Step 1
Investment Menu Oversight
- Confirm an Investment Policy Statement (IPS) is documented and current
- Review fund performance against the IPS benchmarks at least annually
- Document watch-list and replacement decisions with rationale
- Verify the lineup spans core asset classes without unnecessary overlap
- Evaluate the qualified default investment alternative (QDIA)
Step 2
Fee Benchmarking
- Request 408(b)(2) fee disclosures from every service provider
- Benchmark total plan cost against peer plans of similar size
- Separate investment expense, recordkeeping, and advisor fees
- Document the rationale for fee reasonableness in committee minutes
- Re-benchmark at least every 3 years, or after a material change
Step 3
Documentation & Process
- Maintain a written committee charter with named fiduciaries
- Hold and minute committee meetings at least annually
- Retain meeting materials, vendor reports, and decisions in a fiduciary file
- Confirm fidelity bond coverage meets ERISA requirements
- Deliver required participant notices on time (404a-5, QDIA, SAR, etc.)
Step 4
Participant Experience
- Review participation, deferral, and savings rates each year
- Confirm auto-enrollment and auto-escalation features are working as intended
- Provide accessible employee education and 1:1 guidance
- Track outcomes — not just engagement — to measure plan health
Want a second set of eyes?
Our complimentary 401(k) Plan Fitness Assessment walks through this checklist with you and identifies the highest-impact opportunities to reduce fiduciary risk and improve participant outcomes.