Delay in Effective Date of SAS 136

The AICPA has made the decision to delay the effective date of SAS 136 (Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA) to be effective for periods ending on or after December 15, 2021. However, early implementation of this standard is permitted. The new SAS results in changes to the ERISA reporting standards to more clearly define the auditor’s role and work performed for the audit. There were also changes to the requirements in performing an ERISA audit.

In your role as plan management, what changes can you expect?

  • What historically has been known as a “limited scope audit” will now become a 103(a)(3)(c) audit.
  • In order to add more clarity over the information audited by the independent accountant, there will be a two-part opinion to separately address the information covered by the certification and the information not covered by the certification.
  • There will be expanded responsibilities for plan management.

What can you do to prepare:

  • Revisit your procedures to ensure your trustee/custodian is able to certify ALL investments held by the plan.
  • Review your plan documentation to ensure all documents are executed and amendments are current.
  • Revisit your procedures to review for the Plan’s ability to continue as a going concern.


Link to the SAS 136 standard issued by the AICPA

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