The SECURE 2.0 Act of 2022 resulted in a number of changes to employee benefit plans. This article will focus on the required changes that must be implemented and/or formally documented by the end of the 2026 plan year for most qualified plans.
The SECURE 2.0 Act introduced numerous changes to employer-sponsored retirement plans, with effective dates staggered over several years. Although many provisions became operationally effective between 2023 and 2026, plan sponsors were permitted to rely on good-faith operational compliance until formal amendments were required. Most qualified plans and nongovernmental 403(b) plans must adopt formal plan amendments by December 31, 2026. Meaning, even though the operations of the plans may have already changed, 2026 represents the primary documentation compliance deadline.
The following provisions (if applicable to the plan) must be reflected in plan documents by the amendment deadline.
Roth Catch-Up Contributions for High Earners (Effective 2026): Beginning in taxable years starting in 2026, participants with prior-year FICA wages over $150,000 (as indexed for inflation) must make all catch-up contributions if they are age 50+ on a Roth, or after-tax, basis. If the plan is not set up to offer a Roth option, it can’t accept any catch-up contributions from the affected participants.
Also, if high earners are allowed to make Roth catch-up contributions, then the plan will generally need to include a Roth elective deferral feature to accommodate these contributions.In practice, many plans will need to adopt a Roth contribution feature if one is not already in place in order to continue permitting catch-up contributions.
Long-Term, Part-Time (LTPT) Employees: Employees working at least 500 hours in two consecutive years must be allowed to make deferrals into the plan. This rule was effective beginning in 2025, but 2026 would be the second year of evaluation for eligibility into the plan.
Paper Statements: Defined contribution plans are required to provide paper statements to participants at least once per year unless unless participants choose to affirmatively opt out of paper statements and consent to electronic delivery.
The previous paragraphs described the main changes that impacted 2026. If plans implemented any of the other changes from Secure 2.0 such as allowing employees to self-certify hardship distributions, providing matching contributions on student loan payments, and expanding automatic enrollment to name a few, formal amendments need to be completed by December 31, 2026.
It is important to work with your third party administrator to ensure the necessary amendments are completed. Also, you can contact your Hawkins Ash CPAs representative with any additional questions.
