EBSA Voluntary Fiduciary Correction Program, Fiscal Year 2025
Applications processed and correction amounts reported under the Voluntary Fiduciary Correction Program and the Delinquent Filer Voluntary Compliance Program.
One or more figures on this page are pending additional source verification and are shown as unconfirmed rather than estimated.
Year-Over-Year
VFCP applications dropped sharply from 1,162 in FY2024 to 797, a decline worth verifying against the agency’s underlying PDF once located; DFVCP filings rose to 24,513, the highest of the seven years shown.
What Changed in FY2025
A new No Surprises Act reporting line appeared in the fact sheet alongside otherwise-comparable enforcement volumes, just ahead of the incoming administration’s announced FY2026 shift toward cybersecurity as the top priority, continued mental-health and network-adequacy focus, and removal of ESOPs from the national enforcement project list.
The Voluntary Fiduciary Correction Program and its companion Delinquent Filer Voluntary Compliance Program are EBSA's self-correction channels, and participation in them is itself a meaningful signal: a plan sponsor or fiduciary that voluntarily corrects a breach or late filing before EBSA identifies it independently receives materially more favorable treatment than one caught through an investigation, which makes program volume a proxy for how actively the regulated community is self-policing in a given year rather than a measure of enforcement activity directed at anyone.
Duration for voluntary correction is the shortest and most predictable in EBSA's entire enforcement ecosystem, because the process is structured, self-initiated, and does not involve the adversarial dynamics of an investigation — a sponsor identifies the issue, applies the prescribed correction methodology, and receives a no-action letter once the correction is verified. That predictability is exactly why the programs exist: they give fiduciaries and plan administrators a defined, bounded-cost path to resolve common errors — late participant contributions, prohibited transactions, delinquent Form 5500 filings — without the multi-year overhang of a formal civil investigation.
For insurers and plan sponsors, VFCP and DFVCP participation volume is best read as a compliance-culture indicator rather than a risk indicator: rising participation reflects growing awareness of correctable fiduciary errors and a functioning internal compliance process, not rising misconduct, and a plan sponsor's own use of these programs is a mitigating factor — not an aggravating one — in how EBSA and, separately, a fiduciary liability insurer should weigh that sponsor's overall risk profile.
Resolution under both programs is entirely administrative: correction plus any required earnings restoration for VFCP, or a reduced late-filing penalty under DFVCP's fixed fee schedule, with no formal enforcement record attaching once the correction is accepted. Criterica Intelligence frames voluntary correction-program volume as a self-policing signal that should reduce, not increase, a sponsor's modeled exposure relative to comparable plans that have not used these channels, for the fiduciaries, insurers, and funders assessing plan-level compliance risk.
See How EBSA Patterns Inform Duration IntelligenceVFCP applications received: 797, yielding $39.1 million in corrections, per DOL EBSA, FY2025 monetary results (as of 2026-01-30).
VFCP applications dropped sharply from 1,162 in FY2024 to 797, a decline worth verifying against the agency’s underlying PDF once located; DFVCP filings rose to 24,513, the highest of the seven years shown.
No individually named, sourced action for FY2025 has been confirmed for this category yet.
A new No Surprises Act reporting line appeared in the fact sheet alongside otherwise-comparable enforcement volumes, just ahead of the incoming administration’s announced FY2026 shift toward cybersecurity as the top priority, continued mental-health and network-adequacy focus, and removal of ESOPs from the national enforcement project list.
Figures on this page are drawn from official agency publications, cited individually below, and reflect the agency’s own reporting as of the date shown for each figure. They are not Criterica Intelligence model outputs, are not predictions, and are not a measure of any party’s legal exposure or liability. Agencies periodically revise prior-year figures; where a revision is known, both figures are shown with their sources. This page does not constitute legal, investment, or compliance advice.