New Report: DOL Recovers $1.4B From Benefit Plan Violations in FY 2025

EBSA FY 2025 Enforcement Snapshot

• $1.4B recovered for workers and plans
• 878 civil investigations closed
• 253 criminal investigations closed
• $512.5M restored to former employees

Federal regulators recovered $1.4 billion for workers and benefit plans in FY 2025, according to a recent announcement from the Department of Labor (DOL).  

What matters is not just the size of the recoveries, but where they came from. The breakdown shows how the DOL enforces ERISA – and which types of benefit plan violations most often lead to financial correction.

What to Know About the EBSA and Its Annual Report

The DOL’s Employee Benefits Security Administration (EBSA) is responsible for federal benefit plan enforcement under ERISA, covering retirement plans, health plans, and other employee benefits. Its work centers on fiduciary risk, plan operations, and how benefit dollars are managed and protected.

Each year, EBSA releases a summary of its enforcement activity and monetary results. The report shows where violations were found, how they were resolved, and how much money had to be returned to plans and participants. 

EBSA’s FY 2025 enforcement data shows which types of failures most often require correction. Here’s a closer look at where the $1.4 billion came from – and what triggered most of EBSA’s recoveries.

Where the Money Came From

Civil Investigations

EBSA closed 878 civil investigations in FY 2025, with 556 resulting in repayments or required corrective action.

Civil investigations accounted for $714.4 million in recoveries, making enforcement actions the biggest driver of returned funds during the year. 

Many recoveries involved terminated vested participants – that is, former employees who had earned and vested benefits but had not yet received them. EBSA enforcement helped 8,015 former employees collect $512.5 million in outstanding retirement benefits. 

That pattern shows how unpaid benefit plan obligations can outlast employment. 

Informal Complaint Resolution

Many recoveries started with workers raising questions about their benefits. In FY 2025, EBSA Benefits Advisors closed 222,246 inquiries from employees and former employees who contacted the agency about benefit plan problems.

EBSA recovered $468.7 million in benefits for workers and their families through informal complaint resolution. These cases often involved delayed payments, missing paperwork, or plans not following their own terms. The issues were handled without opening a full enforcement case, even though money still had to be returned. 

Benefits Advisors also flagged patterns they couldn’t resolve, such as repeated complaints about the same plan, employer, or service provider. Those referrals led EBSA to open 291 civil investigations.

Abandoned Plan Program

Another source of recoveries came from plans that were never properly wrapped up. In FY 2025, EBSA received 1,858 applications from Qualified Termination Administrators and approved 1,752 plan terminations.

EBSA distributed $117.3 million directly to participants after stepping in to complete plan terminations that employers left unfinished. In many cases, employers shut down, changed ownership, or walked away from plan administration without distributing assets or filing required termination paperwork. The EBSA took over, located the assets, and paid benefits to the people entitled to them.

Non-Monetary Fiduciary Corrections

Not every enforcement outcome involved money changing hands. In FY 2025, EBSA secured 297 non-monetary civil corrections focused on who controlled plans and how oversight worked.

The corrective actions targeted fiduciary governance failures, including:

• removing 15 fiduciaries
• barring 24 individuals from serving as fiduciaries
• appointing 18 new fiduciaries to assume plan oversight
• requiring improvements to missing participant procedures at 49 plans
• imposing 61 global corrections across ERISA-covered health plans

EBSA typically seeks voluntary compliance first. When that didn’t work, enforcement escalated. The agency referred 75 cases to the Solicitor of Labor, with many disputes being resolved before a lawsuit was filed.

Criminal Benefit Plan Enforcement

Some benefit plan cases involved deliberate misuse of plan assets. In FY 2025, EBSA closed 253 criminal investigations tied to how plan assets were handled and who controlled them.

Those investigations resulted in 62 indictments or initial charging events and 45 convictions. Cases involved plan officials, corporate officers, companies, and service providers who diverted assets, falsified records, or abused their fiduciary roles.

Criminal cases make up a small share of EBSA’s overall enforcement activity, but they carry the highest stakes. When benefit plan failures reach this level, the risk shifts from repayment to prosecution.

What These Results Mean for HR and Finance

EBSA’s FY 2025 results point to a few consistent areas where benefit plan oversight breaks down once responsibility stretches across roles. 

These failures tend to follow a predictable path.

• Benefit obligations extend past termination. Assume benefit obligations do not end at termination. Most recoveries tied back to benefits owed years after someone left. HR tracks exits. Finance tracks exposure. Without a shared view of who is still owed benefits, unpaid obligations can sit unnoticed until a participant or regulator raises the issue.
  
• Repeated employee questions are a warning sign. Complaint-driven recoveries show that benefit issues often repeat before they escalate. HR usually hears the questions first. Finance often sees the impact later, once money must be returned. The timing gap affects cost and control.
  
• Plan wind-downs create ownership gaps. Shutdowns, acquisitions, and ownership changes disrupt responsibility, even though plan assets remain regulated. Someone needs clear authority to complete terminations and confirm benefits have been paid.
  
• Fiduciary enforcement focuses on control and follow-through. Many non-monetary corrections centered on who had decision authority and how oversight worked. Documentation and follow-through mattered more than intent. Regulators evaluated outcomes, not internal role boundaries.

For employers, the results reinforce the need for shared ownership across benefit administration. When HR’s participant tracking and Finance’s fiduciary oversight stay aligned, issues are more likely to be resolved internally – before they escalate to regulators.