What are the core fiduciary duties under ERISA?
Last updated October 2, 2026
ERISA imposes four core fiduciary duties, namely loyalty (acting solely in participants' interest), prudence (acting with the care and skill of a knowledgeable expert), diversification of plan assets where applicable, and following the plan documents so long as they comply with the law.
Every ERISA fiduciary — for health plans as much as retirement plans — is held to four core duties:
- Loyalty: decisions must be made solely in the interest of participants and beneficiaries, for the exclusive purpose of providing benefits and paying reasonable expenses.
- Prudence: the "prudent expert" standard — act with the care, skill, and diligence a knowledgeable person would use. Process matters more than outcomes: a well-documented, informed decision is prudent even if results disappoint.
- Diversification: primarily an investment duty, but relevant to funded welfare arrangements.
- Adherence to plan documents: follow the written plan terms unless they conflict with ERISA.
In practice, prudence is where health plan fiduciaries face the most scrutiny — vendor selection, fee reasonableness, and claims administration all turn on whether you can demonstrate a careful, documented process.
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