Statement on Auditing Standards (SAS) No. 136, Forming an Opinion and Reporting on Financial Statements of Employee Benefit Plans Subject to ERISA, addresses the auditor’s responsibility to form an opinion and report on the audit of financial statements of employee benefit plans subject to the Employee Retirement Income Security Act of 1974 (ERISA), and the form and content of the auditor’s report issued as a result of an audit of ERISA plan financial statements.
The SAS also contains a new report format for ERISA section 103(a)(3)(C) audits. For audits of ERISA plan financial statements only, this SAS would apply in place of AU-C section 700, Forming an Opinion and Reporting on Financial Statements, and paragraph .09 of AU-C section 725, Supplementary Information in Relation to the Financial Statements as a Whole (AICPA, Professional Standards). Under the new standard, reports on audits of employee benefit plans will provide users with enhanced transparency about the nature of the audit of a plan as well as the responsibilities of both the plan and the plan’s auditors.
SAS No. 136 is effective for audits of ERISA plan financial statements for periods ending on or after December 15, 2020 and applies only to audits of employee benefit plans that are subject to ERISA. Early implementation is not permitted. (Note: SAS No. 141 defers the effective date of SAS No. 136 to December 15, 2021, and the ASB recommends that SAS Nos. 134–140 be implemented concurrently.)