April 30, 2026 | 6-7 Minute Read
Accurate and complete census data is essential for the successful annual administration of your retirement plan. Each year, your Third-Party Administrator (TPA) will request updated employee information, typically in spreadsheet format. This takes place after the end of the calendar plan year which is typically December, so you would expect this request in the following January.
This article outlines the required census file specifications and answers common questions to help ensure a smooth and efficient submission process.
Annual Census Requirements
The census must include all employees who received compensation at any time during the plan year, regardless of eligibility status or employment status at year-end.
Providing complete and accurate data helps ensure compliance with IRS regulations, supports nondiscrimination testing, and allows for timely plan reporting.
Required File Structure
Your census spreadsheet should include the following fields:
Employee Identification
- Social Security Number: Employee’s nine-digit SSN
- Last Name / First Name: Legal name of the employee
Employment & Ownership Information
- Officer Title: Employee’s title, if applicable
- Ownership Percent: Ownership percentage for any owner
- Family Member & Relationship:
For employees related to a 1% owner, include:- Name of the related individual
- Relationship (e.g., spouse, child)
A “1% owner” is defined as an individual who owns more than 1% of the company at any time during the plan year or the preceding 12 months.
Key Dates
- Date of Birth (MM/DD/YYYY)
- Original Date of Hire (MM/DD/YYYY)
- Termination Date (if applicable)
- Rehire Date (if applicable)
Hours and Compensation
- Hours of Service:
Include all paid hours (worked, vacation, sick leave).- Report actual hours if under 1,000
- Report either actual hours or 1,000 if over
- Gross Compensation:
Total annual compensation including:- W-2 wages
- 401(k)/403(b) deferrals
- Section 125 cafeteria plan deferrals
- Health Savings Account (HSA) pre-tax contributions
Owner-Specific Compensation
For business owners:
- Partners: Provide Schedule K-1 earned income
- Sole Proprietors: Provide Schedule C net income
Additionally, include:
- Draft Schedule K-1 or Schedule C
- Schedule SE (self-employment tax calculation)
Note: Compensation will be adjusted for:
- One-half of self-employment tax
- Retirement plan contributions
Contribution Details
- Employee Pre-Tax Deferrals (401(k)/403(b), including catch-up)
- Employee Roth Deferrals (after-tax, including catch-up)
- Employer Match Contributions
- Safe Harbor Contributions (match or non-elective, if applicable)
Additional Information
- Remarks: Use this field to note special circumstances (e.g., name changes, unique employment situations)
Frequently Asked Questions
- Who should be included in the census?
Include all employees who were paid during the plan year, even if:
- They are no longer employed
- They are not eligible for the plan
Tip: Reconcile total compensation and deferrals with payroll reports to confirm completeness.
- What counts as “compensation for plan purposes”?
Compensation generally includes:
- Wages reported on Form W-2
- Pre-tax deferrals (401(k), HSA, cafeteria plan)
For business owners:
- Sole proprietors: Schedule C income
- Partners: K-1 income
- Do I need to complete the “Other Excluded Compensation” field?
Only complete this field if your plan’s document excludes specific types of compensation (e.g., bonuses). Otherwise, it can be left blank.
- Why are hours worked and employment dates required?
This information is critical for determining:
- Plan eligibility
- Vesting schedules
- Contribution eligibility
- Required Minimum Distributions (RMDs)
- Nondiscrimination testing
Additionally, terminated employees may need to be reported on the IRS Form 5500.
Rehire dates are especially important, as rehired employees may regain eligibility immediately under certain plan provisions.
Best Practices for Accurate Submission
To avoid delays and follow-up questions from your TPA:
- Ensure all required fields are completed for every employee
- Verify totals against payroll reports or Form W-3
- Use the Remarks field for clarifications or special cases
- Submit all requested documentation, especially for business owners
Simplify Census Reporting with Smarter Census Sync©
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Final Thoughts
Providing a complete and accurate census file is a critical step in maintaining your retirement plan’s compliance and efficiency. Taking the time to verify your data before submission can help prevent delays, reduce administrative back-and-forth, and ensure a smooth annual review process.
If you have questions about your census or need assistance preparing your data, your Third-Party Administrator is your best resource for guidance.
Holly Elliott
Holly Elliott is a Senior Retirement Plan Consultant at Benefits² Administrators. She has more than 10 years of experience working with qualified retirement plans.