The EBP audit landscape is evolving rapidly, shaped by rising complexity, tighter expectations, and increasing pressure to do more with cleaner data. Technology is no longer just a support tool—it’s becoming a strategic driver of audit quality, consistency, and scalability. In this post, we share how recent and upcoming innovations are helping firms rethink how EBP audits are performed today and where the profession is headed in 2025 and 2026.
Employee benefit plan audits have always brought their own complexities, but 2025 underscored just how quickly those complexities can compound. Amid ongoing regulatory scrutiny, firms grappled with talent shortages, evolving third-party relationships, and heightened expectations for data quality and fraud awareness. Meanwhile, SECURE 2.0 continued to ripple through the industry, as did the operational impacts of firm consolidation.
What stood out most in 2025 wasn’t a single rule change or tech breakthrough. It was how interdependent everything became. Staffing gaps strained audit quality. Outsourcing introduced oversight risks. Automation unlocked efficiency but raised questions about control and judgment. And throughout it all, plan sponsors and regulators maintained a clear expectation: timely, well-supported audits, no matter how complex the landscape.
Heading into 2026, EBP audits can no longer be viewed as siloed, seasonal work. They’re evolving with the industry, and firms must evolve with them. The five predictions below outline where EBP audits are headed, and what smart firms are doing now to prepare.
What 2025 revealed:
Facing compressed timelines and limited capacity, many firms leaned on both domestic and offshore outsourcing to meet audit demand. But while it relieved pressure, it also surfaced familiar pain points: inconsistent documentation, unclear supervision, and limited EBP-specific expertise.
What changes in 2026:
Outsourcing isn’t going away. But neither is the responsibility auditors hold for quality and judgment. Regulators and peer reviewers continue to emphasize one thing: You can outsource the work, but not the accountability.
Expect increased scrutiny around:
• How firms supervise outsourced teams
• Whether EBP nuances are understood across borders
• Documentation that supports auditor oversight
In short, outsourcing without integration will become a liability.
Why it matters:
Firms that view outsourcing as a governed process, not just a capacity fix, will be best positioned to scale without compromising quality. It’s not about who performs the work, but how well it aligns with your audit standards.
What 2025 revealed:
AI showed up in EBP audits, often indirectly. Whether in data wrangling, exception identification, or workflow automation, it nudged its way into processes without becoming the centerpiece.
What changes in 2026:
AI’s influence will be harder to ignore. Even if your team doesn’t directly implement AI, chances are your plan sponsors, service providers, or internal systems already have. And that changes the equation.
Auditors will need to:
• Evaluate how AI-generated data impacts risk assessments
• Document professional judgment in light of AI suggestions
• Establish clear guardrails around automation used in testing
Why it matters:
AI can be a force multiplier, but only with the right governance. The firms leading the way won’t just adopt new tools. They’ll ensure every insight still ties back to audit objectives and professional standards.
What 2025 revealed:
Mergers, acquisitions, and private equity interest surged in 2025. For many EBP audit teams, the impact was indirect but significant: new systems, shifting leadership, and evolving methodologies.
What changes in 2026:
As consolidation continues, EBP teams may find themselves navigating new templates, unfamiliar software, or even changes in client ownership.
Integration risk becomes real when:
• EBP expertise gets diluted across broader service lines
• Methodologies are unified without EBP-specific adjustments
• Teams lose continuity in the audit process
Why it matters:
EBP audits leave little room for error. Successful firms will actively manage transitions to ensure that quality doesn’t suffer. Treating EBP audits as a post-M&A afterthought is a fast track to audit failure.
What 2025 revealed:
Auditors spent much of 2025 flagging which SECURE 2.0 provisions applied to which clients. But implementation? That was all over the map. Plan sponsors varied widely in how they interpreted and executed the rules.
What changes in 2026:
Now that SECURE 2.0 is more deeply embedded, auditors will need to shift focus:
• Assess whether amendments were properly adopted
• Confirm eligibility and contribution changes were executed accurately
• Communicate findings clearly to clients and providers
The errors you’ll uncover in 2026 won’t be about knowing the rules. They’ll be about how the rules were applied.
Why it matters:
As SECURE 2.0 becomes embedded in plan operations, auditors will be expected to identify breakdowns early and assess their impact with precision.
What 2025 revealed:
Plan sponsors and participants faced rising threats: account takeovers, fraudulent distributions, and third-party breaches. Even when dollar amounts were immaterial, the reputational and operational risk was clear.
What changes in 2026:
Fraud and cybersecurity are now audit-level risks. That means:
Why it matters:
Fraud and cyber risks directly affect participant trust. Auditors who proactively address these risks will be better positioned to support audit quality and stakeholder confidence.
What This Means for EBP Audit Firms
For firms handling 401(k) audits, 2026 will be about more than capacity. It’ll be about intentionality. The trends ahead aren’t isolated, they're interwoven across every stage of the audit process.
To stay ahead, firms should:
In short, EBP audits demand rigor, not routine. Treating them like routine engagements is a recipe for falling behind.
Learning from the Profession
EBP audits aren’t more complex because the fundamentals have changed, they’re more complex because expectations have. At AuditMiner, we study how those expectations evolve across firms, not to offer cookie-cutter answers, but to spotlight where risk tends to emerge. As 2026 unfolds, the firms that adapt with intention and learn from the profession as a whole will be the ones that lead with quality, confidence, and clarity.
As firms get settled into 2026, accurate data collection and workflow efficiencies will undoubtedly be top of mind. In our recent whitepaper, Auditing Beyond Spreadsheets, we outline the cycle of incomplete data, strategic insights from real industry data, and practical solutions to move beyond spreadsheet limitations. Give it a read!
