5500 audit requirement

[Tom]

A plan was required to be audited in the past but no audit required now since the # of account holders dropped just below 100 as of 1/1/2023 and 1/1/2024.   Looking ahead to 2025 - what if the account holders go to 105 as of 1/1/2025?  I'm reading that the plan can file as per the prior year if between 80 and 120 account holders.  So in this case the plan could file 5500-SF for and no audit for the 2025 plan year? Filing the 5500 wrong certainly has bad consequence which is why I'm asking.  Thank you.

 

[Bruce1]

Top of page 11 of 5500-SF 2023 instructions: 

The plan (a) covered fewer than 100 participants at the beginning of the plan year 2023, *or* (b) under 29 CFR 2520.103-1(d) was eligible to and filed as a small plan for plan year 2022 and did not cover more than 120 participants at the beginning of plan year 2023. 

 

As long as your plan filed 5500-SF in 2024 you could file a 5500-SF in 2025 if the plan had less than 120 participants.