A Prudent Start to the New Year: Your Fiduciary Checklist for 2026

As one year closes and another begins, retirement plan sponsors often find themselves racing to meet fiduciary deadlines—finalizing filings, sending notices, and checking boxes to stay compliant. But once the dust settles, January offers an opportunity to take a step back and look at the retirement-plan big picture.

The new plan year isn’t just about starting fresh; it’s about making sure your fiduciary process is structured, documented, and defensible. Whether you manage a small plan or oversee a complex one, having a clear fiduciary framework can make the difference between scrambling at year-end and leading with confidence all year long.

That’s where a well-organized fiduciary checklist comes in. The LoVasco Retirement Plan Consulting team has our own proprietary "Fiduciary Checklist" that we share with clients to make sure nothing is overlooked or goes too long without a review. While some items on this checklist are annual reminders or obligations, others have a three-year time horizon.  

That said, now that the new year is here and the mad race to the calendar-year finish line is behind us, let’s take a moment to walk through the checklist together, so that 2026 is off on the right foot, whether you are working with LoVasco or not.

Process Over Perfection

The goal of fiduciary oversight isn’t to complete every task on a rigid annual schedule—it’s to maintain a prudent, repeatable process.

Under ERISA, fiduciaries are expected to act solely in the interest of plan participants, document their decisions, and periodically review plan operations to ensure compliance and reasonableness. Not every task happens every year. Some—like investment policy statement reviews or benchmarking recordkeeping fees—might be done every three years. Others—like distributing required notices or reviewing plan operations—should be done annually.

What matters most is that your fiduciary process is clearly defined, consistently followed, and properly documented. A checklist helps you prove it.

The Five Pillars of Fiduciary Oversight

At LoVasco, we use a structured fiduciary checklist to help plan sponsors maintain procedural discipline and transparency. It covers five key areas:

1. Plan Governance & Oversight

Start with your foundation.

• Conduct fiduciary training for all committee members at least annually.
• Maintain up-to-date committee charters and bylaws.
• Keep detailed meeting minutes documenting key decisions and rationales.
• Verify fiduciary insurance coverage—including E&O and fidelity bonds—is sufficient.

Strong governance sets the tone for every other area of plan management.

2. Investment Oversight

A prudent investment process is ongoing, not a one-time occurrence.

• Review your Investment Policy Statement (IPS) for continued relevance and compliance.
• Evaluate fund performance versus benchmarks and peers, documenting changes and rationale.
• Benchmark fees and expenses regularly to ensure reasonableness.
• Assess your default investment (QDIA) to confirm it remains suitable for your participant population.

Even if fund changes aren’t needed, maintaining clear documentation of why you made—or didn’t make—a change is crucial.

3. Service Provider Management

Your service providers are extensions of your fiduciary process.

• Conduct periodic RFPs for recordkeepers (typically every 3–5 years).
• Review service levels, performance metrics, and any potential conflicts of interest.
• Confirm your recordkeeper’s cybersecurity protocols and request annual SOC 2 Type II reports.
• Require multifactor authentication (MFA) for participant accounts whenever possible.

Vendor oversight is often an overlooked fiduciary duty—yet it’s where many compliance issues can arise.

4. Participant Outcomes & Communication

Fiduciary responsibility doesn’t end with plan operations; it extends to participant engagement and education.

• Provide education sessions on retirement planning and plan features.
• Encourage automatic enrollment and auto-escalation to drive participation.
• Monitor deferral rates, participation levels, and loan activity to spot trends or red flags.
• Offer access to financial wellness tools or personalized advice when possible.

Ultimately, helping participants achieve better outcomes fulfills the spirit of fiduciary responsibility—not just the letter of the law.

5. Compliance & Reporting

Finally, ensure your plan remains on solid regulatory footing.

• File Form 5500 by the required deadline (or extension).
• Complete annual nondiscrimination testing (ADP/ACP, Top-Heavy, etc.).
• Verify timely deposit of employee deferrals.
• Retain plan records for at least six years as required under ERISA.

For large plans (100+ participants), engage an independent auditor annually. And if you uncover operational errors, take advantage of the IRS’s correction programs to address them proactively.

Documentation Is Your Best Defense

If the Department of Labor ever audits your plan, their focus isn’t only on what you did—it’s on how you did it. A fiduciary checklist, maintained throughout the year, becomes your first line of defense.

Keep a centralized fiduciary file that includes meeting minutes, investment reviews, service provider evaluations, and participant education materials. The ability to demonstrate a prudent process—backed by documentation—goes a long way in reducing fiduciary risk.

In the eyes of regulators, good intentions aren’t enough. What matters is being able to prove that you acted prudently, consistently, and in the best interests of participants.

Start the Year Strong and Plan Ahead

A fiduciary checklist isn’t just a compliance tool; it’s a roadmap for clarity, confidence, and protection. By revisiting it at the start of each year, plan sponsors can stay ahead of deadlines, align with best practices, and strengthen the governance that underpins their plan.

We’ve distilled our approach into a resource you can use to guide your own process.

➡️ Download LoVasco’s Fiduciary Checklist

Because fiduciary excellence isn’t about doing everything—it’s about doing the right things, for the right reasons, and being able to prove it.