Read off 8,166 Form 5500 filings for 2024 that reported what the plan paid its auditor. Not a survey, and not a quote: this is money that changed hands.
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The median plan-paid 401(k) audit fee in 2024 was $12,600 for plans with 100 to 249 participants, the band a plan lands in the year it first needs an audit. (2,066 filings reported a fee.)
The step between one band and the next is smaller than the spread inside a single band. A plan in the 100 to 249 band paid anywhere from $8,500 to $17,160 across the middle half of filings.
Bar: 25th to 75th percentile. Line and figure: median. Bands with fewer than 30 filings reporting a fee are not plotted.
1 group withheld for having fewer than 30 filings with a reported fee.
Read this one with plan size in mind. Full scope audits concentrate among the largest plans, so comparing the two columns across all plans mostly compares plan sizes. Within the 100 to 249 band the two are close, and a clear gap only opens above about 1,000 participants. 96% of audited filings used the 103(a)(3)(C) option.
A plan year counts as first-time when the plan has no audited filing in any earlier year in this data, which starts at 2021. 3,144 of 61,241 2024 filings were first-time, but only 142 of those reported a fee, and first-time audits concentrate in the smallest plans, which report least often. The difference below is small and the sample is not a fair cross-section.
States with fewer than 30 filings reporting a fee are withheld rather than printed thin.
Both years are drawn the same way, so the change is comparable, but it is a change in what reporting plans paid rather than a price index. 2025 filings are still arriving and are not shown here.
Everything on this page is produced by one script from the Department of Labor’s public Form 5500 datasets. No figure is typed in by hand.
Source. The DOL’s “Latest” Form 5500 bulk files for plan years 2021 through 2025: Schedule H for the auditor, the audit fee and plan assets, the main Form 5500 for the sponsor, state and participant count, and Schedule C Part I item 2 for compensation paid to service providers. Kept: filings that name an independent accountant, are a plan rather than a pooled investment entity, and carry a 401(k) or 403(b) feature code.
What a fee here is. The plan’s own audit fee line on Schedule H. Where that is blank we fall back to direct compensation on Schedule C, but only where the provider’s EIN is the same EIN Schedule H names as the accountant, so the figure is money paid to that auditor and not to somebody else. Of 61,982 audited filings for 2024, 8,166 carried a fee: 6,958 from Schedule H and 1,208 recovered from Schedule C.
The limitation that matters most. A fee appears only when the plan paid it. Sponsors frequently pay the auditor from company funds, which is permitted, and those fees are absent from the filings entirely. Coverage is 13.2% overall and varies sharply by size, from 7.2% in the 100 to 249 band to 43.7% at 5,000 participants and above. A median taken across all plans without regard to size would therefore be pulled up by the large plans that report most often, which is why every figure here is banded.
A second, smaller limitation. Schedule C only requires a provider to be listed once it received $5,000 or more, so the Schedule C part of the data cannot see a cheap audit. Schedule H has no such floor, which is why it is preferred where both exist.
Sample sizes are printed beside every figure, and a group with fewer than 30 reporting filings is withheld rather than shown thin. Percentiles are linear-interpolated.
2025 is partial. Calendar-year 2025 returns were not due until July 31 2026, October 15 with an extension, and the DOL’s bulk files lag behind that. 16,843 filings are loaded so far against 61,982 for 2024, so 2025 is excluded from the tables above.
Corrections. If you believe a filing has been read wrongly, write to corrections@401kaudithelp.com. Every correction is logged with its date and reason.
Download the aggregate tables (CSV)
Aggregates only. The CSV holds no plan-level or firm-level rows, so nothing in it identifies a sponsor.
In 2024 filings, the median plan-paid audit fee was $12,600 for plans with 100 to 249 participants, $19,057 at 1,000 to 2,499, and $31,683 at 5,000 or more. Half of plans in the 100 to 249 band paid between $8,500 and $17,160, so the spread inside a band is wider than the step between bands. These are fees the plan itself paid, read off 8,166 filings that reported one. Where the employer pays the auditor from company money the fee never appears on the Form 5500 at all, which is most plans, so this is the going rate among plans that pay from plan assets rather than the going rate for an audit.
Not in what plans pay from plan assets. Two ways of asking agree. Comparing different plans in 2024, the median first-time audit was $17,936 against $16,695 for a recurring one, on only 142 first-time filings that reported a fee. Following the same plan from its first audited year into its second, the second year costs more rather than less: up about 6% at the median, against about 5% for plans that were already recurring, so first-timers track the ordinary year-on-year drift instead of falling back from a high opening fee. The median hides a wide spread, though: about a third of those plans did pay less in year two and about a third paid sharply more, so this is a tendency across plans and not a rule any one plan follows. One caveat also matters. A first-year setup charge billed separately and paid from company funds never reaches the Form 5500, so if an onboarding premium exists it is being billed outside the plan and this data cannot see it. Expect the real difference to be in the work rather than the invoice: a first audit has no prior-year workpapers to lean on and opening balances have to be established.
Not at the plan sizes where most sponsors ask. Comparing like with like in 2024, plans with 100 to 249 participants paid a median $12,600 under 103(a)(3)(C), and full scope audits of plans that size were not cheaper. A clear gap only opens above about 1,000 participants, where a full scope audit has materially more investment testing to do. The headline difference across all plans is mostly plan size rather than scope, because full scope audits are concentrated among the largest plans. It is also close to moot for most plans: 96% of audited 401(k) and 403(b) filings in 2024 used the 103(a)(3)(C) option.
Because a Form 5500 reports an audit fee only when the plan paid it. A sponsor that pays its auditor from company funds, which is both common and permitted, reports nothing, and the fee is invisible to this or any other analysis of the filings. Of 61,982 audited 401(k) and 403(b) filings for 2024, 8,166 carried a plan-paid fee, or 13.2%. Coverage is thinnest among small plans and best among the largest, so a figure read across all plans without regard to size would be pulled upward by the plans most likely to report.
Looking for who does these audits? The auditor directory lists 784 firms from the same filings.