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.