Labor Department says it has primary authority to interpret and enforce ERISA Title I

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Confirm whether statutory text, regulations, or authoritative agency materials designate the Department of Labor as having primary interpretive and enforcement authority over Title I of ERISA.

Source summary

The U.S. Department of Labor filed an amicus brief with the Third Circuit urging it to affirm a lower court’s dismissal of fiduciary breach claims in Barragan v. Honeywell Int’l Inc. The DOL argued the district court correctly found the plan sponsor did not breach duties because the plan allowed fiduciary discretion and the plaintiff made only a bare allegation about forfeitures. The brief asserts ERISA’s protections focus on honoring promised participant benefits and that there is no per se rule preventing fiduciaries from using forfeited employer contributions to reduce future employer contributions.

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Latest fact check

The Department of Labor's Jan. 30, 2026 press release on its amicus brief explicitly states that the department "has primary authority to interpret and enforce provisions of Title I" of ERISA. That position is consistent with other DOL filings (e.g., Office of the Solicitor briefs) and DOL guidance, although DOL materials (EBSA Enforcement Manual) also explain that the IRS retains primary authority over certain tax-qualification/minimum-standards aspects of Title I (Parts 2 and 3) for qualified plans. Verdict: True — the Department of Labor did state it has primary authority to interpret and enforce Title I of ERISA, as shown in the DOL press release and other official DOL documents, while recognizing limited IRS responsibilities for tax/qualification matters.

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Timeline

Update · Jan 31, 2026, 04:14 AMTrue
The Department of Labor's Jan. 30, 2026 press release on its amicus brief explicitly states that the department "has primary authority to interpret and enforce provisions of Title I" of ERISA. That position is consistent with other DOL filings (e.g., Office of the Solicitor briefs) and DOL guidance, although DOL materials (EBSA Enforcement Manual) also explain that the IRS retains primary authority over certain tax-qualification/minimum-standards aspects of Title I (Parts 2 and 3) for qualified plans. Verdict: True — the Department of Labor did state it has primary authority to interpret and enforce Title I of ERISA, as shown in the DOL press release and other official DOL documents, while recognizing limited IRS responsibilities for tax/qualification matters.
Original article · Jan 30, 2026
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