2026 Recordkeeping Survey Flags a Conflict Fee Benchmarking Alone Won't Catch
PLANSPONSOR's 2026 Recordkeeping Survey found that plan sponsors are increasingly expected to scrutinize not just their recordkeeper's stated fee, but what the recordkeeper earns behind that fee through participant-level revenue — a distinction industry voices say standard fee benchmarking doesn't surface on its own.
Read the original at PLANSPONSORPLANSPONSOR's 2026 Recordkeeping Survey highlights a distinction that's becoming central to how plan committees are expected to evaluate their recordkeeper relationship: the stated fee a plan pays is not the same as everything a recordkeeper earns from that relationship. Survey commentary describes an "embedded conflict" in some recordkeeping arrangements — revenue the recordkeeper collects from participants directly, separate from and in addition to the fee negotiated with the plan sponsor — that a simple fee-benchmarking exercise won't necessarily surface.
The survey also points to a shift in cadence expectations: where plan sponsors have traditionally benchmarked their recordkeeper every three to five years, industry voices cited in the survey argue that provider oversight increasingly needs to be a standing, annual committee agenda item rather than a periodic exercise.
Separately, the survey recorded a 44.8% year-over-year increase in employers participating in 401(k)/403(b) pooled employer plans (PEPs) — 10,797 adopting employers in 2026, up from 7,454 the prior year.
Why this matters for advisors: the core question the survey raises — "what does our recordkeeper earn from our participants behind the stated fee, and did we knowingly approve that?" — is precisely the direct-vs-indirect compensation distinction that a plan's own Schedule C filing is built to answer, if read carefully. It's a real-world illustration of why total-fee visibility, not just the headline recordkeeping rate, is the more complete question for a fiduciary to be asking.