The American Institute of CPAs (AICPA) has published a resource for auditors of the ERISA plan financial statements.

The Employee Benefit Plans Industry FAQ with Illustrative Auditor’s Reports for Initial Year of Implementation of SAS No. 136, as Amended, provides nonauthoritative guidance on auditor’s reports for the initial implementation year of AICPA Statement on Auditing Standards (SAS) No. 136 — Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA, as amended.

AICPA audit and attest standards team senior manager Linda Delahanty said: “In the AICPA Auditing Standards Board’s continued efforts to improve the relevance and communicative value of auditor reporting, SAS No. 136 specifically addresses the significant public interest associated with audits of employee benefit plans subject to ERISA. This document provides helpful, non-authoritative guidance to auditors who are now implementing SAS No. 136 for 2020 plan years. Next year, all EBP auditors will implement SAS No. 136 and we expect that they will find the illustrative auditor reports in this FAQ helpful.”

About EBP SAS 136:

  • In July 2019, the AICPA Auditing Standards Board (ASB) issued as a final standard, Statement on Auditing Standards (SAS) No. 136, Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA(EBP SAS).
  • The EBP SAS has been codified in AU-C section 703, Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA, of AICPA Professional Standards and amended by various other SASs subsequent to its issuance.
  • The EBP SAS, as amended, prescribes certain new performance requirements for an audit of financial statements of employee benefit plans subject to ERISA, and changes the form and content of the related auditor’s report. It should not be adapted for plans that are not subject to ERISA.
  • SAS No. 136 can be viewed on the AICPA’s website under recently issued standards; however, AU-C section 703 of AICPA Professional Standards contains the most up-to-date version of SAS No. 136, as amended.



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