EBSA Enforcement Efforts Yield $1.4 Billion in Recoveries
•February 10, 2026
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Why It Matters
The recoveries protect millions of participants and reinforce ERISA’s mandate, while the enforcement actions deter misconduct and improve plan governance across a $14.6 trillion benefits landscape.
Key Takeaways
- •$1.4B recovered FY2025, slight rise from FY2024.
- •556 civil investigations generated $715M recoveries.
- •222,246 informal inquiries resolved, yielding $468.7M.
- •VFCP self‑corrections produced $39.1M recoveries.
- •62 indictments, 45 convictions from criminal probes.
Pulse Analysis
The Employee Benefits Security Administration (EBSA) continued to leverage its enforcement authority in fiscal year 2025, returning $1.4 billion to retirement, health and welfare plans. While the figure edges up from the $1.384 billion recovered a year earlier, it still trails the 2023 peak of $1.435 billion, underscoring a modest but steady recovery pace. EBSA closed 878 civil and 253 criminal investigations, reflecting a balanced focus on both compliance violations and outright fraud. These actions reinforce the agency’s mandate under ERISA to safeguard the assets of roughly 155 million workers and retirees.
The bulk of the 2025 recoveries stemmed from civil investigations, with 556 cases delivering $715 million—over half of the total. Informal complaint resolution proved equally potent: benefits advisors handled more than 222,000 inquiries, producing $468.7 million in returns and prompting 291 new investigations. Targeted programs added further value; the Voluntary Fiduciary Correction Program generated $39.1 million by encouraging self‑reporting, while the No Surprises Act inquiries recovered $67 million for patients burdened by unexpected medical bills. Together, these mechanisms translate enforcement into tangible participant relief.
Beyond the dollar figures, EBDA’s enforcement yielded significant non‑monetary outcomes: removal of 15 fiduciaries, appointment of 18 new trustees, and 297 civil corrections that improve plan governance. Criminal probes resulted in 62 indictments and 45 convictions, sending a clear deterrent signal to plan sponsors and service providers. As plan assets hover around $14.6 trillion, sustained oversight is critical for market stability and investor confidence, suggesting EBSA will likely intensify its proactive programs in the years ahead.
EBSA enforcement efforts yield $1.4 billion in recoveries
The Department of Labor’s Employee Benefits Security Administration (EBSA) recovered $1.4 billion for retirement, health and welfare plans in fiscal year 2025, reflecting continued enforcement activity even as total recoveries remain below recent highs.
EBSA said the $1.4 billion returned to plans, participants and beneficiaries represents a slight increase from the $1.384 billion recovered in fiscal year 2024, but remains below the $1.435 billion recovered in fiscal year 2023. In fiscal year 2025, EBSA closed 878 civil investigations and 253 criminal investigations. EBSA is responsible for investigating and enforcing the Employee Retirement Income Security Act, which sets standards for private-sector benefit plans and protects participants and beneficiaries.
More than half of total recoveries, about $715 million, came from enforcement actions tied to 556 civil investigations. Recoveries for terminated vested participants accounted for a significant portion, helping 8,015 former employees in defined benefit pension plans collect $512.5 million in owed benefits.
Nearly half of all recoveries, $468.7 million, resulted from informal complaint resolutions handled by EBSA benefits advisors, who closed 222,246 inquiries during the year. Some complaints led to further enforcement. EBSA opened 291 investigations based on benefits advisor referrals and referred 75 cases for litigation.
See also: ‘Significant’ changes afoot for federal employee benefits unit
Additional recoveries came from targeted programs. The abandoned plan program returned $117.3 million. The Voluntary Fiduciary Correction Program (VFCP) allows plan fiduciaries to self-report and correct mistakes without facing penalties, resulting in $39.1 million in recoveries. EBSA also recovered $67 million through No Surprises Act (NSA) inquiries, which protect patients from unexpected out-of-network medical bills by requiring improper payments to be corrected rather than levying fines. Benefits advisors received more than 27,000 NSA complaints in 2025.
Non-monetary outcomes included removing 15 fiduciaries, barring 24 individuals from service, appointing 18 fiduciaries, improving missing participant procedures for 49 plans, implementing 61 global corrections and achieving 297 non-monetary civil corrections overall. Criminal investigations resulted in 62 indictments or initial charging events and 45 convictions involving plan officials, corporations and service providers.
EBSA highlighted how its enforcement translates into participant relief. In one example, participants in a frozen 401(k) plan received $33.6 million in distributions. Other cases led to over $22 million in payments from life insurance and claims administration corrections affecting thousands of participants and providers.
The agency oversees roughly 2.8 million health plans, 837,000 private pension plans and 521,000 other welfare benefit plans, covering 155 million workers, retirees and dependents, with assets totaling about $14.6 trillion.
This article was originally published on BenefitsPRO, a sister site of HR Executive. For more content like this delivered to your inbox, sign up for BenefitsPRO newsletters here.
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