No. The statutory rule requires employees to complete 1,000 hours and 12 months of service. Here's an example. A plan with a 1,000-hours-of-service eligibility requirement hires an employee on November 11, 2005. The employee completes 1,000 hours of service on June 8, 2006, but is not eligible to join the plan at that time. He or she must wait until November 10, 2006, to complete the 12-months-of-service requirement and enter the plan on the next plan entry date.

The employee should not be permitted to enter on the plan entry date that follows June 9, 2005, just because he or she has completed 1,000 hours of service. Although some employers may consider it an act of generosity, the law does not allow employers to permit employees to become participants as soon as 1,000 hours of service have been completed.

IRC 410(a)(3)(A) and ERISA 202(a)(3)(A)