Is an ERISA Bond Required?
Generally, ERISA requires each person who handles an employee benefit plan’s funds or other property to be bonded, subject to statutory and regulatory exceptions. The rules depend on the person, plan, and handling activity.
ERISA § 412 generally requires bonding for people who handle plan funds or other property, including some fiduciaries and service providers. DOL explains that not every fiduciary must be bonded: a fiduciary who does not handle plan property is not bonded solely because of fiduciary status. Certain plan types and arrangements may qualify for exemptions, so test the particular facts rather than applying the rule by job title.
DOL’s bulletin explains the handling test, who is responsible for ensuring bonding, bond form and surety requirements, and how to calculate the amount. Determine which people can cause plan property to be paid, transferred, or accessed; then check if an exemption applies. Confirm the plan is protected under the bond and document the amount, covered handlers, and renewal dates. This bond is distinct from fiduciary liability insurance.
Related Coverage
Providers That List This Coverage
Sources
- Understanding Your Fiduciary Responsibilities Under a Group Health Plan. U.S. Department of Labor, Employee Benefits Security Administration; Who Is a Fiduciary?; What Is the Significance of Being a Fiduciary?; Bonding. Accessed 2026-09-25.
- Field Assistance Bulletin No. 2008-04: Guidance Regarding ERISA Fidelity Bonding Requirements. U.S. Department of Labor, Employee Benefits Security Administration; Q2 pp.2–3. Accessed 2026-09-25.
- Field Assistance Bulletin No. 2008-04: Guidance Regarding ERISA Fidelity Bonding Requirements. U.S. Department of Labor, Employee Benefits Security Administration; Q5–10 pp.3–5; Q35–38 pp.18–20. Accessed 2026-09-25.
