Voluntary Fiduciary Correction Program Checklist

Summary

This checklist provides step-by-step guidance for private employers on the use of the Department of Labor's (DOL's) Voluntary Fiduciary Correction Program (VFCP) to correct and self-report fiduciary violations or prohibited transactions under the Employee Retirement Income Security Act (ERISA). The most recent VFCP amendments are effective as of March 17, 2025. See 90 Fed. Reg. 4,192 (Jan. 15, 2025), restating 71 Fed. Reg. 20,261 (Apr. 19, 2006). The most significant change in the 2025 Amendments is to implement a self-correction component (SCC) program for certain failures. The VFCP also provides limited Internal Revenue Code (IRC) excise tax relief for certain prohibited transactions that can be corrected under the VFCP.