Auditor Independence Resource Center

The AICPA, DOL, and SEC all have rules regarding auditor independence. The DOL rules apply to all employee benefit plan auditors, the AICPA rules also apply to those auditors who are members of the AICPA, and the SEC's rules apply to auditors of plans that file on Form 11-K with the SEC. The Center has compiled the following resources to assist employee benefit plan auditors in better understanding the independence rules that apply to them and their firms.

Documentation of Review of AICPA Independence Requirements Where Nonattest Services Are Performed for an Employee Benefit Plan Audit Client
This tool is intended to assist CPAs performing nonattest services for employee benefit plan audit clients in documenting their assessment of whether the nonattest services impair their independence, whether they have performed any “prohibited” nonattest services, and whether their understanding with the client has been established and documented in writing.

Frequently Asked Questions:  Application of the Independence Rules to Affiliates of Employee Benefit Plans
This document will help members better understand how the definitions and guidance provided in Interpretation No. 101-18 apply to employee benefit plan audits through the use of answers to frequently asked questions (FAQ).

DOL Interpretive Bulletin 75-9 (29 CFR 2509.75-9)
The DOL's independence rules are codified in DOL Interpretive Bulletin 75-9 (29 CFR 2509.75-9).

AICPA Independence Rules
The AICPA's independence rules are codified in AICPA Rule 101, Independence. 

DOL and AICPA Independence Rule Comparison
This document compares the more common DOL and AICPA independence rules that affect auditors of employee benefit plans, and provides a discussion of the differences.

Independence Inquiries

AICPA Hotline and Contact Information

The Professional Ethics Division educates members and promotes the understanding of ethical standards contained in the Code by responding to member inquiries on the application of the Code to specific areas of practice. To access the Ethics Hotline, dial (888) 777-7077, (select option 2, then 3) or e-mail us at


EBSA Hotline: 866-463-3278

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