Why a “Limited‑Scope” 401(k) Audit Still Looks Closely at HR and Payroll

The truth is simple: what used to be called a “limited‑scope” audit (now more formally an ERISA Section 103(a)(3)(C) audit) does not mean less work for HR or payroll. It only changes how the auditor tests certain investment information. The parts of the 401(k) plan audit that live in HR and payroll stay very much in scope.

Let’s break that down in plain English and talk about what you can do to prepare.