The most useful posture for a plan sponsor reading the 2026 Schedule A guidance is the one that distinguishes between what the Department of Labor has now made explicit and what it has, in our reading, gestured toward without committing to. Both categories matter for plan-year reporting. They matter in different ways, and they call for different responses.

The guidance was published as a series of revisions and clarifications rather than as a single restatement of the schedule's purpose. That presentation has consequences. It allows the Department to address discrete points without re-opening every interpretive question that the schedule raises; it also means that what the guidance does not say is, in some cases, more instructive than what it does. Below is our reading of the operative portions, organized by what we believe a sponsor can rely on and what we believe a sponsor should treat as directional rather than dispositive.

What the revisions now require

Three changes have moved from interpretive question to settled expectation in our reading of the 2026 guidance.

  1. Indirect compensation must be disclosed in the year it is earned, not the year it is paid. The schedule's prior treatment of bonus payments and retention incentives produced reporting timing that varied with carrier accounting conventions. The revised guidance is explicit: indirect compensation attributable to the plan year is reportable in that plan year, regardless of when the underlying payment is disbursed. This affects, in particular, carrier-to-broker volume bonuses and trailing commissions, which had been reported inconsistently across the industry.
  2. Non-monetary compensation is in scope when it is provided "in connection with" the plan. The revisions clarify a question that had divided practitioners for several plan years. Conference attendance, training credits, sales-incentive recognition — items that had often been characterized as marketing rather than compensation — are now expressly reportable where the link to the plan can be established. The Department's framing is functional, not formal. Internal carrier classification of a payment as something other than compensation is not, on its own, sufficient.
  3. The disclosure obligation rests with the filer. This was implicit before; it is now explicit. A carrier's Schedule A figures may be the working data set, but the filer cannot rely on the carrier's classification of what is and is not reportable. Reconciliation against the broker compensation agreement is now squarely the filer's responsibility, and a filer who reports only what the carrier provides is in a weaker position than a filer who has documented an independent reconciliation.

What the revisions imply but do not say

Two further questions are, in our reading, addressed by the guidance only by inference. We think both are worth attention.

The first is whether the revised treatment is retroactive in any meaningful sense. The Department has not announced enforcement priorities for prior plan years on these issues. It has also not said that prior plan years are out of scope. A sponsor whose prior filings would not have satisfied the revised guidance should not assume the question is closed; nor should a sponsor assume that amendment is necessary as a defensive matter. The right reading, in our view, is that the Department has surfaced an analytical framework it considers sound and will apply to filings going forward — but that historical filings prepared in good faith on a different framework are not, by that fact alone, presumptively deficient.

The revisions describe an analytical framework. They do not, on their face, alter the standard against which good-faith historical filings will be examined. That distinction is important, and easy to miss.

The second is whether the new explicit treatment of "in connection with" non-monetary compensation extends to relationships between brokers and third-party service providers — not only between brokers and carriers. The guidance is silent. Our reading is that the framework applies; the Department's language is structural rather than carrier-specific. But the silence is real, and a sponsor's posture in the interval before clarifying guidance is issued should be documented.

What we are recommending to clients

For the current plan year, we are recommending three operational steps in addition to whatever changes the filer's existing workflow already produces.

None of these steps are new in principle. The 2026 guidance does not change what compliance looks like for a filer who was already doing the analytical work. It changes the posture for a filer who was not — and it shifts the burden of demonstrating the analysis from the carrier to the plan.

Part of the Plan Year 2026 series. The analysis above reflects Cherry Park's reading of the Department of Labor's published guidance and is not legal advice. Sponsors with specific compliance questions should consult ERISA counsel; sponsors with specific filing questions are invited to request a confidential plan review.