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Who Audits Benefit Plans

SEC registrants that offer benefit plans are required to file an annual Form 11-K containing an auditor’s report of the benefit plan’s financial statements. Different from post-employment benefit plans covered by ERISA, 11-K annual reports apply to employee stock purchase, savings, and similar plans with interests that constitute securities.

The audit landscape of benefit plans requiring Form 11-K represents a smaller market than ERISA plans. For example, 977 benefit plan audit opinions were filed on Form 11-K in 2020. In comparison, over 14,500 ERISA plans were audited in the same year.  

Benefit Plan Market Share

Predictably, the major global and national audit firms hold the largest market share of benefit plans. Though somewhat surprisingly, the Big Four firms do not exclusively share the biggest slice of the market. In both 2019 and 2020, global firm BDO held the fourth position, respectively auditing 5.8% and 6.4% of this audit market. This edged out Big Four firm PwC, who ranked a close fifth in both years.

The firms comprising the top five auditors of benefit plans across 2019 and 2020 did not change. However, the order outside the top five firms changed slightly from one year to the next. Grant Thornton, Baker Tilly, and BKD each experienced a growth in their market share in 2020. In contrast, Crowe and Moss Adams experienced modest decreases.

Despite little change at the top, there is variety among audit firms in this market. The top 10 firms combined hold slightly more than 50% of the market. In 2019, the top 10 firms held 52.4% of the market. A total of 119 other firms shared the remaining 47.6%. Comparatively, in 2020, the top 10 firms slightly expanded their footprint, collectively holding 53.9% of the market; 111 other firms shared the remainder.

Market Share by Number of Plans per Firm

Furthermore, variety outside the top firms means that two-thirds of the firms competing for this market sign off on less than five audit opinions for benefit plans annually. Nearly 50% of firms in the benefit plan audit market in both 2019 and 2020 audited just one or two plans.


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