How to Complete Your 401(k) Annual Census: A Step-by-Step Checklist
If your company sponsors a 401(k) plan, submitting accurate annual census data to your Third-Party Administrator (TPA) is one of the most important tasks in your retirement plan administration process. This data drives everything from employer match calculations to required 401k compliance testing—and delays can lead to costly errors.
In this guide, we’ll walk you through exactly what information your TPA needs and how to ensure your TPA census submission is complete and on time.
What Is a 401(k) Annual Census?
A 401(k) annual census is a comprehensive report of employee data that your TPA uses to:
- Perform required compliance testing (ADP, ACP, top-heavy tests)
- Calculate employer matching contributions accurately
- Determine participant vesting percentages
- Identify highly compensated employees (HCEs) and key employees
- Prepare your plan’s annual Form 5500 filing
The census includes data for all employees—not just those participating in the plan—because eligibility and testing requirements apply company-wide.
What to Include in Your 401k Census Checklist
While specific requirements may vary based on your plan document, most TPA census submissions require the following categories of information.
- Employee Identifying Information
For every employee on your payroll during the plan year, provide:
- Full legal name
- Social Security number or employee ID
- Date of birth
- Original date of hire (even if the employee was rehired)
- Termination date and/or rehire date, if applicable
- Current employment status (active, terminated, retired, deceased, on leave)
- Compensation Data
Compensation figures are critical for employer match calculations and compliance testing. Be sure to use the compensation definition specified in your plan document, which may differ from W-2 wages.
- Gross compensation for the plan year
- Bonuses, overtime, and commissions (if tracked separately per plan terms)
- Hours and Service Information
Hours worked are essential for determining eligibility and vesting. Even salaried employees may need hours tracked depending on your plan’s requirements.
- Total hours worked during the plan year
- Hours for part-time and salaried/exempt employees
- Ownership and Related Party Information
This information is used to identify highly compensated employees (HCEs) and key employees for 401k compliance testing.
- Ownership percentage for each owner
- Family relationships to owners (spouse, child, parent, grandparent)
- Controlled group or affiliated service group details, if applicable
- Deferral and Contribution Data
Include payroll-related contribution information:
- Pre-tax deferral amounts by employee
- Roth deferral amounts by employee
- Catch-up contributions for employees age 50 and older
- Loan repayments processed through payroll (if applicable)
Common 401(k) Census Mistakes to Avoid
Even experienced plan sponsors can make errors in their retirement plan census submissions. Watch out for these common pitfalls:
- Omitting terminated employees — They must still be reported for the plan year.
- Using the wrong compensation definition — Always refer to your plan document.
- Excluding hours for salaried employees — Many plans still require this data.
- Outdated ownership percentages — Update after any business changes.
- Late submissions — This delays compliance testing and contribution calculations.
5 Tips for a Smooth TPA Census Submission
- Request your TPA’s census template early — Each TPA may have specific formatting requirements.
- Coordinate with your payroll provider — Many payroll systems can export census data in the required format.
- Review data for accuracy before submitting — Double-check compensation figures and employee counts.
- Include all employees — Even those who didn’t participate or who terminated during the year.
- Submit as early as possible — This allows time for questions, corrections, and timely filings.
Why Timing Matters for Your 401k Plan Administration
Your TPA manages census data for many plans simultaneously during peak filing season. Submitting your 401(k) annual census promptly ensures your plan receives the attention it needs and helps avoid:
- Delayed employer contribution calculations
- Rushed compliance testing that may miss errors
- Late Form 5500 filings and potential penalties
- Additional stress during an already busy time
Next Steps
Completing your 401k census checklist doesn’t have to be overwhelming. Start by contacting your TPA to confirm their specific requirements, then work with your payroll provider to gather the necessary data.
If you have questions about preparing your retirement plan census or need assistance with your 401k plan administration, contact your TPA for guidance.
Disclaimer: This article is provided for general informational and educational purposes only and does not constitute legal, tax, or professional advice. Plan requirements vary based on individual plan documents and applicable regulations. Please consult with your TPA, legal counsel, or qualified retirement plan advisor for guidance specific to your situation. This content is intended to assist with understanding 401(k) census requirements but does not guarantee compliance with ERISA, IRS, or DOL requirements. |
401(k) Annual Census Submission Checklist: Click Here to access a copy of the below checklist resource in PDF format.
Use this checklist to ensure you submit complete and accurate census data to your Third-Party Administrator (TPA). Timely submission helps ensure accurate contribution calculations, proper compliance testing, and on-time Form 5500 filing.
Section 1: Employee Identifying Information
Provide the following for ALL employees—not just plan participants:
Employee Identifying Information | |
☐ | Full legal name |
☐ | Social Security number (or employee ID) |
☐ | Date of birth |
☐ | Date of hire (original hire date, even if rehired) |
☐ | Date of termination, if applicable |
☐ | Date of rehire, if applicable |
☐ | Employment status (active, terminated, deceased, retired, on leave) |
Section 2: Compensation Data
Compensation must match the definition in your plan document, which may differ from W-2 wages:
Compensation Data | |
☐ | Gross compensation for the plan year (per plan document definition) |
☐ | Bonus amounts (if tracked separately per plan terms) |
☐ | Overtime pay (if tracked separately per plan terms) |
☐ | Commissions (if tracked separately per plan terms) |
Section 3: Hours and Service Information
Hours are required for eligibility and vesting calculations, even for salaried employees:
Service Information | |
☐ | Total hours worked during the plan year |
☐ | Hours tracked for salaried/exempt employees (if required by plan) |
☐ | Hours for part-time employees |
Section 4: Ownership and Related Party Information
Required for highly compensated employee (HCE) and key employee testing:
Ownership Information | |
☐ | Ownership percentage for each owner |
☐ | Family relationships to owners (spouse, child, parent, grandparent) |
☐ | Any changes in ownership during the plan year |
☐ | Controlled group or affiliated service group information (if applicable) |
Section 5: Deferral and Contribution Data
Provide payroll-related contribution information:
Contribution Data | |
☐ | Pre-tax deferral amounts by employee |
☐ | Roth deferral amounts by employee |
☐ | Catch-up contributions (for employees age 50+) |
☐ | Loan repayments processed through payroll (if applicable) |
Section 6: Before You Submit
Final Review | |
☐ | Verify ALL employees are included (including terminated employees) |
☐ | Confirm compensation definition matches plan document |
☐ | Review ownership percentages for accuracy |
☐ | Use TPA’s preferred format or template |
☐ | Submit data to TPA ASAP to ensure timely filings |
Helpful Tips
• Contact your TPA early to request their specific census template. • Coordinate with your payroll provider to export data in the required format. • Don’t forget terminated employees — they must be reported for the plan year. • Submit early to allow time for questions and corrections. |
Questions? Contact your TPA for assistance.
Disclaimer: This checklist is provided for general informational and educational purposes only and does not constitute legal, tax, or professional advice. Plan requirements vary based on plan documents and applicable regulations. Please consult with your TPA, legal counsel, or qualified retirement plan advisor for guidance specific to your plan. This document is intended to assist with compliance but does not guarantee compliance with ERISA, IRS, or DOL requirements.
