BENEFITS DIGEST

Fifteen states now have some automatic enrollment of public sector employees, but nearly half of US states prohibit it.

Auto-enrollment is one of those retirement plan features that sounds wonderfully simple in a sales presentation. “We’ll automatically enroll employees, boost participation, and help people save.”

Separate regular and Roth catch-up elections can misclassify contributions when a participant stops saving midyear. TruePlan’s 26-payroll example shows a saver who quits contributing after 18 pay periods with dollars already labeled catch-up even though total contributions never reached the regular limit. Those dollars aren’t catch-up contributions in the example, and the employee may have made more Roth contributions than intended. A single election whose tax treatment changes only after the regular limit is reached avoids the problem, because nothing gets labeled catch-up until the participant is actually past the cap.

Marsh projects a $25,500 employee contribution limit for 401(k), 403(b), and eligible 457 plans in 2027. It estimates an $8,500 catch-up limit for most eligible workers ages 50 and older and $11,750 for those ages 60 through 63. The estimates incorporate September’s inflation reading and remain provisional until the IRS announces the official limits, which usually arrive in late October or early November.

Williams Mullen extends its year-end checklist series to governmental and church plans outside ERISA. Amendment deadlines depend on the type of plan and the change involved: for many nongovernmental plans, amendments documenting optional SECURE and SECURE 2.0 features already in use are due December 31, 2026, while required amendments can have later deadlines and governmental plans generally have additional time, a distinction the [IRS clarified this month](https://content.govdelivery.com/accounts/USIRS/bulletins/42b06be). Sponsors should document operational changes now so the eventual amendment matches how the plan actually works. The Roth catch-up requirement for participants whose prior-year FICA wages topped $150,000 applies for 2026 and rewards a payroll-system check. Also on the list: the IRS now issues determination letters for individually designed 403(b) plans, and the 2023 proposed forfeiture regulations, which generally require defined contribution forfeitures to be used within 12 months after the close of the plan year in which they arise, can be relied on now.

The Slott Report maps the fork in the road between Roth IRA and Roth 401(k) distribution rules, a useful desk reference as mandatory Roth catch-ups push more plan money into Roth accounts.

With the mandatory Roth catch-up regime live for participants who earned over $150,000 in prior-year FICA wages, Lyndsey Barnett walks through the correction framework when a high earner's catch-up contributions land pre-tax by mistake. Timing matters: errors caught before W-2 filing are fixed by transferring the funds and correcting wage reporting, later discoveries require an in-plan Roth rollover with 2026 errors corrected by December 31, 2027, and no correction is generally required if the erroneous amount is $250 or less.

a useful one-stop review for anyone catching up after a summer vacation.

Experts from Groom Law Group and CAPTRUST answer questions concerning retirement plan administration and regulations.

As the SECURE 2.0 Act deadline for mandatory catch-up contributions for some plan participants looms, many retirement plan sponsors are beginning to amend their plan documents to meet its requirements.

Housing costs, everyday expenses, and debt are making it harder for workers to increase their retirement savings. Goldman Sachs Asset Management's 2026 retirement survey, released Wednesday, finds the share of workers who increased their retirement savings fell to 39 percent from 55 percent a year ago, while the share who cut savings nearly doubled to 14 percent. The pressure points differ by generation, and 61 percent of surveyed workers report working outside their primary job, most of them out of financial need. Only 58 percent of savers call themselves on track, down from 68 percent last year. For sponsors, the survey argues for plan design that treats emergency savings, debt, and retirement as one connected problem rather than competing line items.

With 59% of Americans lacking the savings to cover an emergency expense, employers are rethinking financial wellness benefits, from emergency savings programs to retirement plans to AI-powered financial advice.

Employers that provide an emergency savings solution for their employees saw improved contribution rates in their retirement plans, according to a report published by Vanguard.

Ted Benna says the new employer-funded plan is designed to help workers cover short-term financial needs without tapping retirement savings.

As part of a multi-bill markup, the Senate HELP Committee advanced legislation to make pension-linked emergency savings accounts (PLESAs) more attractive, along with boosting funding for the DOL’s Employee Ownership Initiative.

Sponsors correcting certain automatic-enrollment mistakes get more time to restore missed employer matches under the [updated retirement plan correction procedure](https://www.irs.gov/pub/irs-drop/rp-26-34.pdf). The period deemed reasonable for those corrective matches increases from 6 months to 12 months after the month correct deferrals begin. The October 22 update also incorporates SECURE 2.0’s broader self-correction rules and its treatment of inadvertent overpayments, with exceptions and safeguards that still need to be checked for each error. Separately, the [new IRA correction procedure](https://www.irs.gov/pub/irs-drop/rp-26-33.pdf) opens May 1, 2027 for four specified types of failure, including certain missed required minimum distributions and rollover errors. That program requires an IRS application, generally with a $3,500 fee. Comments on both procedures are due January 20, 2027.

NAPA reports that the IRS regulations implementing the SECURE 2.0 automatic enrollment requirements for 401(k) and 403(b) plans have cleared White House review and could be released in the near future. [OIRA’s docket](https://www.reginfo.gov/public/do/eoDetails?rrid=1440111) confirms the Treasury rule, Automatic Enrollment Requirements Under Section 414A, concluded review on October 16, likewise cleared with changes made during review. Sponsors covered by the mandate have been operating on proposed rules and notices while the final text sat in review.

Mayer Brown unpacks a September 18 IRS Employee Plans newsletter correcting the widespread assumption that every SECURE and SECURE 2.0 amendment is due December 31, 2026. Under the newsletter as the firm reads it, discretionary changes a plan has already put into operation generally do need amendments by the end of 2026, while many required amendments come due only after the relevant provision lands on an IRS Required Amendments List, with later dates generally applying to collectively bargained and governmental plans. A separate [Notice 2026-33](https://www.irs.gov/pub/irs-drop/n-26-33.pdf) extends the deadline for optional qualified long-term-care distribution amendments to December 31, 2027. The firm’s practical point is to track the document deadline and the operational compliance date separately.

The Foundation’s answer to the recurring question of when SECURE 2.0 amendments are due is an inventory, not a single date. Amendments on the IRS 2024 Required Amendments List are generally due December 31, 2026, the 2025 list generally runs to December 31, 2027, and certain collectively bargained and governmental plans have until the end of 2028 and 2029. Discretionary changes follow their own timing, and operating in compliance now matters independently of when the plan document catches up.

Candace Finn untangles which SECURE and SECURE 2.0 amendments are actually due December 31, 2026, drawing on the IRS’s recent clarification. For required changes, the IRS’s annual amendment list helps determine when the paperwork is due, and a provision does not land on that list until the underlying guidance is settled. The Roth catch-up requirement, for example, is expected on the 2027 list, which would push its amendment deadline out to the end of 2029, and future lists are expected to cover automatic enrollment, long-term part-time employees and remaining required minimum distribution changes. More time to amend the document does not mean more time to comply with the underlying requirement, which applies on its own schedule. Discretionary provisions are the ones still on the 2026 clock. Under Notice 2024-2, optional SECURE 2.0 features a plan already operates, such as Roth employer contributions, generally must be documented by December 31, 2026. Finn’s practical warning is to resist checking every optional box in the amendment package, because a provision the recordkeeper and payroll system cannot administer is a plan document saying one thing while operations say another.

The SECURE Acts raised the statutory required minimum distribution ages to 72 and then 73, but Code section 401(a)(9) sets the latest permissible commencement date, not the plan’s own. A defined benefit plan whose document independently defines its required beginning date as April 1 following age 70 1/2 may keep starting benefits at 70 1/2, a result the preamble to Treasury’s 2024 final RMD regulations confirms directly. The answer lives in the plan document rather than the statute, so check whether yours states its own age or merely incorporates the Code by reference. The amendment clock runs either way; required SECURE amendments, including the technical RMD updates, are generally due by December 31 of this year.

December 31, 2026 is the deadline for most calendar-year retirement plans to document, in a formal amendment, the CARES, SECURE and SECURE 2.0 changes they’ve been operating under, from Roth catch-ups for high earners and long-term part-time eligibility through super catch-ups, higher RMD ages and the optional early-withdrawal provisions. Informal IRS guidance from September 16 suggests some SECURE 2.0 amendment deadlines may slip, but the firm still recommends documenting everything implemented as part of this year-end. The discretionary review is where the litigation lessons show up. The firm suggests forfeiture language that makes the allocation choice a plan-design decision rather than a fiduciary one, claims procedures with limitations and venue provisions, a look at arbitration language, and beneficiary procedures that answer what happens after a divorce or when a beneficiary dies before being paid.

December 31 is the deadline for 2026 required minimum distributions, and this plain-English refresher has two details worth stealing for participant communications. First, the 1959 drafting glitch. SECURE 2.0 assigns people born that year to both age 73 and age 75, and until proposed regulations finalize the fix, the safe answer is 73. Second, the first-year trap. Waiting until April 1 to take a first RMD means two taxable RMDs land in the same year. On inherited accounts, beneficiaries under the 10-year rule generally owe annual withdrawals in years one through nine only when the original owner died on or after his required beginning date, and the IRS’s penalty waiver for those missed annual withdrawals ended after 2024. The missed-RMD excise tax is 25 percent, dropping to 10 with prompt correction.

The initial 2026-2027 Priority Guidance Plan lists 121 projects the agencies intend to prioritize, and the benefits entries sketch the year ahead. From the One Big Beautiful Bill Act, the plan includes Trump Account guidance, regulations on the expanded employer child care credit, and guidance on the paid family and medical leave credit. The retirement entries run from an update to the Employee Plans correction program and a new program for correcting IRA mistakes, through SECURE 2.0 guidance including the saver’s match and student-loan matching contributions, to electronic-delivery modernization and defined benefit funding guidance. Other projects address fringe benefits and VEBAs, the tax-exempt trusts some employers use to fund benefits. For executive pay, the plan lists regulations on the deduction limit for high pay at public companies and the parallel excise tax at tax-exempt organizations. The list sets the agencies’ priorities for the coming year. It doesn’t change existing requirements or promise when any project will be finished.

The deadline depends on what the amendment does. Most plans adopting optional features under SECURE and SECURE 2.0 must update their documents by December 31, 2026. Required changes follow a different schedule tied to IRS guidance and the agency's annual Required Amendments lists, and later deadlines apply to certain union-negotiated plans, governmental plans, and public school 403(b) plans. These are deadlines for updating plan documents, not permission to delay following rules already in effect. One wrinkle from the IRS's September clarification helps sponsors: if the IRS later issues guidance about an optional feature a plan has already adopted, the further amendment implementing that guidance gets its own, later deadline. The IRS expects to issue final regulations on automatic enrollment, long-term part-time workers, and required minimum distributions, and the Roth catch-up requirement is expected to join the 2027 list, pushing that amendment deadline to December 31, 2029.

Mercer's GRIST covers the December 31, 2026 deadline for adopting SECURE and SECURE 2.0 plan amendments and fills in the rest of the year-end picture, including amendment deadlines under the CARES Act, the Miners Act, and the 2020 disaster-relief law, what the 2024 Required Amendments List already requires, and the routine interest rate and mortality table updates that plans without incorporation-by-reference language must adopt by year end. It covers both individually designed and preapproved plans.

Milliman turns this month's IRS clarification into a plan-by-plan checklist. The dividing line is whether an amendment is required or discretionary. Optional SECURE and SECURE 2.0 features a plan has already put into operation, such as letting participants take employer contributions as Roth, generally must be reflected in a plan amendment by December 31, 2026, under Notice 2024-2's extension, with more time for collectively bargained, governmental, and public school 403(b) plans. Required amendments follow the annual Required Amendments List and often land later: the Roth catch-up requirement is expected on the 2027 list, making its deadline generally December 31, 2029. The forward calendar matters too. Automatic enrollment, long-term part-time, and remaining minimum-distribution requirements will each be listed only after final regulations, which are not expected to apply earlier than the plan year starting six months after they are issued. The near-term task for calendar-year plans is an inventory of optional features already in operation, because those carry the year-end 2026 date.

A year-end checklist for companies that sponsor retirement plans and executive pay arrangements. On the plan side, amendments documenting optional SECURE and SECURE 2.0 changes already in operation are due December 31 for calendar-year plans, while required changes can have later deadlines. On the executive side, three items reward attention before year-end. Social Security and Medicare taxes on deferred compensation are generally owed when the pay vests, not when it is paid, so amounts that vested in 2026 need payroll taxes handled by December 31. Elections to defer pay earned in 2027 must also be made by December 31, with narrow exceptions. And documentary problems in deferred-compensation arrangements can often be corrected without penalty if caught before the amounts vest, which makes a year-end review worth scheduling. Public companies should also confirm that equity-plan share reserves will cover grants planned through 2028.

The IRS's August rollover guidance is optional today and a signal for tomorrow. Notice 2026-49, issued August 12, offers plans a five-step process and four sample forms for direct rollovers between plans and IRAs, as SECURE 2.0 required. Foley reads the signals in the fine print: future guidance may disallow paper checks, bar demands for Medallion signature guarantees, a bank's stamp vouching for a signature, that stall rollovers today, and let receiving plans "reasonably conclude" a sending plan is qualified, a lighter standard than the 2014 revenue ruling it would relax. Comments are due October 23.

For most plans, amendments documenting optional SECURE and SECURE 2.0 changes already in operation are due December 31, 2026. Required amendments wait until the end of the second year after they appear on an IRS Required Amendments List, which for the Roth catch-up mandate is expected to mean December 31, 2029, per Haynes Boone's read of the September 16 bulletin. Bricker Graydon's Lyndsey Barnett adds the question sponsors skip: whether the person signing the amendment actually has authority to adopt it. If the board never delegated amendment authority, board action is required, and auditors ask for the resolutions, not just the amendment. One caution: a later amendment deadline doesn't postpone the requirement to operate the plan correctly in the meantime.

[Notice 2026-28](https://www.irs.gov/pub/irs-drop/n-26-28.pdf) led the Digest when it arrived August 5, and comments on it close October 16. Ogletree Deakins's Friday analysis is a prompt to revisit three details before then. The six-month eligibility period is an election an employer makes in its written policy, not an automatic change. Leave required or paid by a state or local program can help an employer qualify for the credit even though it doesn't increase the amount. And an employer can't claim twice for the same funded benefit, though it may use the premium method for an insured portion and the wage method for a portion paid separately from general assets. Employers can rely on the notice for tax years beginning after 2025 until proposed regulations arrive. It's one of three open comment windows. Comments on the [Trump Account and dependent-care assistance proposal](https://www.federalregister.gov/documents/2026/08/11/2026-16314/employer-contributions-to-trump-accounts-and-nondiscrimination-rules-for-dependent-care-assistance) we covered August 11 close Friday, September 25, and the Saver's Match questions from [Notice 2026-48](https://www.irs.gov/pub/irs-drop/n-26-48.pdf) close October 5.

The question plan sponsors have been asking, answered from the source. Discretionary SECURE and SECURE 2.0 amendments, the features a plan chose to adopt, must be adopted by December 31, 2026, the Notice 2024-2 deadline, now about three and a half months away. Required amendments run on a different clock: generally the end of the second calendar year after the provision lands on the IRS's annual Required Amendments List. Collectively bargained plans, governmental plans and public-school 403(b) plans get later dates. The article also previews what will land on future Required Amendments Lists, including final rules on automatic enrollment, long-term part-time employees and required minimum distributions, each carrying its own two-year amendment window. The task between now and year-end is sorting every adopted feature into the right column.

Section 324 of the SECURE 2.0 Act directs Treasury to issue sample forms, procedures, and protocols that make rollovers easier to complete and more consistent across plans.

The IRS recently released Notice 2026-49, proposing sample forms and a standardized five-step process for rollovers to eligible retirement plans under Section 324 of the SECURE 2.0 Act.

The August Monthly Minute reminds plan sponsors of the upcoming SECURE 2.0 plan amendment deadline and highlights a Fourth Circuit decision reflecting the litigation impact of a delayed ERISA appeal determination.

Foley's reminder that years of CARES, SECURE, and SECURE 2.0 operation may not yet be reflected in plan documents: when operations, communications, and the document diverge, the amendment deadline is the cleanup moment. A practical December 31 checklist starter.

A second read on the SECURE 2.0 section 324 rollover package, with attention to the four sample forms and what recordkeepers will need to change to support direct electronic transfers.

Implementing SECURE 2.0 section 324, the IRS proposes four optional sample forms and standardized procedures for rollovers between employer plans or between a plan and an IRA, aiming to replace today's paper-check-and-fax friction with a predictable process. Use of the forms would be optional and no safe harbor attaches yet; comments are due October 23, 2026.

Experts from Groom Law Group and CAPTRUST answer a practical question on the timing of 403(b) restatements and SECURE 2.0 amendments.

As the December 31, 2026 deadline approaches for adopting SECURE and SECURE 2.0 amendments, Milliman examines a key decision for defined benefit plan sponsors: whether to retain a required start date for benefit distributions that is earlier than the new later statutory required beginning date for RMDs, which has been raised to age 72, 73, and 75 depending on the participant's birth year.

Retirement plans face a critical compliance deadline arriving on December 31, 2026.

The December 31, 2026 deadline is fast approaching for most non-governmental plan sponsors to amend their tax-qualified retirement plans to comply with changes made by the SECURE Act of 2019, the CARES Act, the Taxpayer Certainty and Disaster Relief Act of 2021, and the Secure 2.0 Act (the “Acts”).

We also explore how Section 315 and Section 101 of the SECURE 2.0 Act impact plan mergers and family attribution rules, as well as why engaging ERISA counsel for a legal opinion is essential now that the IRS no longer issues determination letters for coverage testing.

Investment menu rulemaking and outstanding SECURE Act and SECURE 2.0 guidance dominated the regulators’ newly posted lists.

The US Treasury also posted a rule list that provides SECURE 2.0 guidance including required minimum distributions.

Michael Doshier, who leads retirement at LPL, argues that state auto-IRA mandates give advisers a natural opening to discuss employer-sponsored plans, and he points to a Maryland assisted-living company that chose its own plan over the state program. The Boston College research he cites suggests a relationship between state mandates and private plan formation, which is not the same as proof that one causes the other. Federal startup tax credits and the coming Saver’s Match round out the pitch. No state requires an employer to adopt a 401(k).

Calendar-year plan administrators have several notice deadlines approaching on December 2. Reinhart’s roundup identifies annual default-investment, automatic-enrollment and applicable safe-harbor notices, with requirements depending on the plan’s design. It also covers plan-amendment deadlines, PBGC reporting relief, preparation for the Saver’s Match and health-plan developments, including commentary on enforcement of surprise-billing arbitration awards.

Finhabits estimates that 13.6 million Latino adults could meet the income requirements for the federal Saver’s Match, which applies to eligible contributions beginning with the 2027 tax year. That’s potential eligibility, not a count of people who will enroll or receive a match. Its report models $615 billion to $1.02 trillion in retirement balances over 30 years using assumed participation, contributions, matching payments and investment returns. Those figures are illustrations, not forecasts. The report’s practical emphasis is on making retirement saving easier to understand and sustain, including guidance in English and Spanish. An incentive won’t bring people into the system by itself if opening an account, making contributions or claiming the match remains confusing.

Comments closed October 5 on Notice 2026-48, the IRS’s framework for delivering the Saver’s Match, the Treasury-funded 50 percent match on the first $2,000 of retirement savings that replaces the Saver’s Credit, with deposits starting in 2028 for 2027 contributions. ERIC backs the registration path, which moves the money into a worker’s plan as an ordinary rollover, arguing it lets workers benefit without forcing plans to build new tracking systems or send employee data to the government, and it warns against an automatic match path that could require real-time eligibility feeds to the IRS. NAGDCA supports a conduit IRA, asks for clear Roth-conversion procedures without withholding at conversion, and wants final regulations promptly plus good-faith transition relief. The IRS has confirmed that plans won’t be required to accept the contributions at all, which may become its own design question for sponsors.

A day before the IRS began notifying workers about the saver's match, the senator who wrote it proposed doubling it. Senate Finance Committee Ranking Member Ron Wyden introduced the Savers Match Enhancement Act, which would raise the federal match from 50 percent to 100 percent of the first $2,000 saved, for a maximum of $2,000 a year, index that cap to inflation, roughly double the income phaseout ranges so more middle-income workers qualify, and convert the match from a pretax deposit into an after-tax Roth contribution. For a single filer, eligibility would phase out between $42,500 and $57,500 instead of the current $20,500 to $35,500. The match program itself starts in 2027, and the increase remains a proposal.

The IRS is telling workers the federal government will match their retirement savings. [Notice CP321J](https://www.irs.gov/individuals/understanding-your-cp321j-notice) goes to filers who claimed the saver's credit on 2025 returns or whose income was in the eligible range. The match takes effect in 2027. Eligible workers will receive a federal contribution of up to 50 percent of the first $2,000 they save, a maximum of $1,000. The money goes directly into the worker's retirement account, with the first deposits arriving in 2028. Plans can choose whether to accept the federal matching deposits. In PSCA's survey, 45.6 percent of plan sponsors say they will not, 16 percent had not heard of the program, and 2.4 percent plan to accept. Eligible workers whose plans do not accept the deposits may be able to direct the match to a traditional IRA that does, per [Notice 2026-48](https://www.irs.gov/pub/irs-drop/n-26-48.pdf), and amounts under $100 can be taken as a refundable credit instead. Since about half of Americans do not know what the saver's credit is even as it phases out, employers should be ready for participant questions when the notices land.

Senate Finance ranking member Ron Wyden introduced [S. 5507](https://www.congress.gov/bill/119th-congress/senate-bill/5507) on Thursday to enlarge the saver's match before it starts. The match, created by SECURE 2.0, deposits a federal matching contribution directly into a saver's IRA or workplace plan account. Under current law it pays 50 percent of the first $2,000 contributed, a maximum of $1,000, phasing out between $41,000 and $71,000 of income on a joint return. The bill would double the rate to 100 percent, raise the maximum to $2,000 a year, index it, treat the match as Roth money, and lift the joint phase-out range to $85,000 through $115,000. The existing match is scheduled to begin in 2027. Wyden's bill would make it more generous, but it has not become law, and with the Senate out until after the election no action is expected soon. Recordkeepers are already building for the 2027 launch, and sponsors will field participant questions about the match either way.

New Treasury guidance addresses the Saver's Match, retirement-plan rollovers and employer contributions to Trump Accounts.

A sponsor-side walkthrough of Notice 2026-48, the August guidance on the federal match of up to 50 percent of contributions, capped at $1,000 a year, that replaces the Saver's Credit for tax years beginning after 2026. The useful frame is the decision tree, because plans are not required to accept the match money at all. Accepting it brings amendment, transmission, and recordkeeping choices. The walkthrough also flags seven operational questions Treasury and the IRS say they are still working through, from tax treatment to claiming mechanics. First federal payments arrive in 2028. Comments on the open questions close October 5.

Timed to counter the recurring claim that 401(k) tax benefits flow mostly to the wealthy, the American Retirement Association's Hidden in Plain Sight study finds workers earning between $50,000 and $100,000 pay 9.1% of federal income taxes and collect more than 30% of retirement tax benefits once employer contributions are counted, while households above $200,000 pay 71.4% of the taxes and receive 16.7% of the benefits. ARA chief Brian Graff argues working class Americans get the lion's share, a case built for the Saver's Match era arriving in 2027.

The Plan Sponsor Council of America asked sponsors whether they will amend their plans to accept Saver's Match contributions when the federal match arrives for tax year 2027. About 36% are considering it, 47% say no, mostly because their workforces out-earn the income caps, and 16% had never heard of it.

Groom collects its August publications in one place, spanning DB plan funding rules, 45S credit and Saver's Match guidance, dependent care nondiscrimination, the wellness program enforcement relief, the e-delivery proposal, and the tobacco surcharge litigation.

Groom Law Group and CAPTRUST experts answer the question. The Saver's Match is voluntary for 403(b) plans, not required. Eligible low- and moderate-income savers can receive a federal matching contribution of up to $1,000 for taxable years beginning after December 31, 2026, and plans that choose to accept the deposits will need amendments and new administrative procedures under Notice 2026-48.

Section 103 of SECURE 2.0 replaces the Saver's Credit with a matching contribution from the federal government, and its implementation raises a series of decisions for plan sponsors. Seyfarth surveys the open questions about how the new match will operate.

Groom's Q&A-format read of Notice 2026-48 and what it signals about the forthcoming Saver's Match proposed regulations.

Treasury and the IRS announced that they will propose regulations on the Saver's Match and begin implementing an Executive Order to create a federal IRA savings program for private-sector workers without coverage.

Treasury and the IRS announce their intent to propose regulations implementing the Saver's Match program under section 6433, the SECURE 2.0 provision paying federal matching contributions of up to $1,000 directly into the retirement accounts of eligible low- and moderate-income savers for tax years beginning after December 31, 2026. The notice requests comments by October 5, 2026 on eligibility, claiming and payment mechanics, financial-institution reporting, and treatment of erroneous payments.

PLANSPONSOR's coverage of the Saver's Match announcement, detailing how eligible Americans could receive federal retirement contributions of up to $1,000 per year and what the rulemaking will need to resolve before the program's 2027 start.

The government launches the regulatory process for SECURE 2.0’s Saver’s Match and takes a first step toward implementing the Executive Order establishing TrumpIRA.gov.

December 31, 2026 is an important retirement plan amendment deadline, but it isn’t the deadline for every change. Segal explains which amendments are due this year, which follow the IRS’s separate timetable for individually designed plans, and which qualify for later deadlines. The year-end date applies to non-governmental single-employer plans, including 403(b) plans not maintained by public schools, while collectively bargained plans have until the end of 2028 and governmental plans until the end of 2029. The date matters most for the long list of discretionary features that trigger amendments only if a plan has adopted them, such as in-service distributions at 59½, emergency savings accounts, Roth treatment of employer contributions, the $7,000 cash-out limit, student loan matching and hardship self-certification. Extra time to amend the paperwork didn’t give plans extra time to follow the law. The amendments must reflect when each provision actually took effect for the plan.

EBRI has quantified SECURE 2.0's student loan match. If every plan sponsor adopted the optional feature, which treats an employee's student loan payments as elective deferrals for matching purposes, EBRI estimates $11.2 billion a year would flow to participants' accounts at a 4 percent match cap and $20.2 billion at 6 percent. The population is bigger than sponsors may assume: roughly 20 percent of 401(k) participants ages 25 to 69 carry student loan debt, including more than a third of those under 30. Among eligible workers ages 25 to 34, 75.5 percent of those with student debt participated, compared with 84.1 percent without it. Borrowers also had lower median balances across income and tenure groups, with the largest gap, about 45 percent, among participants in their 40s. For sponsors weighing the feature, the report offers a first sizing of who could benefit and by how much.

The adoption story behind the EBRI numbers we ran Tuesday and Thursday. One in five 401(k) participants between 25 and 69 carries student debt, and among those borrowers the under-saving runs deep. Sixty-one percent defer less than 6 percent of pay, a pattern EBRI finds at every income level. SECURE 2.0's answer lets employers match student-loan payments as if they were 401(k) deferrals. eBay had already budgeted for every employee to take the full match and already had 96 percent participation in its plan, which is why its benefits manager calls adding the student-loan match “kind of a no-brainer,” per HR Dive's account.

SECURE 2.0 lets employers match an employee's student loan payments as if they were 401(k) deferrals, and EBRI's new 23-page issue brief estimates who could benefit and by how much. About one in five 401(k) participants aged 25 to 69 carried student debt between 2019 and 2023. Debt holders participate less often, 75.5 percent versus 84.1 percent, and hold less: median balances run 18.5 percent lower, with the gap widest, 45 percent, among participants in their 40s. If every plan adopted the feature, EBRI projects $11.2 billion a year in additional matching contributions at a 4 percent match cap and $20.2 billion at 6 percent. Candidly, a student-debt benefits vendor, helped fund the research. Trade coverage from [PLANSPONSOR](https://www.plansponsor.com/universal-adoption-of-student-loan-match-program-could-add-20-2b-annually-to-dc-plans-per-ebri) and [401(k) Specialist](https://401kspecialistmag.com/student-loan-debt-heavily-impacts-401k-success-ebri) focused on the adoption math.

EBRI put numbers on the SECURE 2.0 student loan match. If every defined contribution plan adopted the provision, matching contributions on loan payments would add an estimated $20.2 billion a year to retirement accounts at a 6 percent match cap, or $11.2 billion at 4 percent. The demographics explain who would benefit. About 20 percent of 401(k) participants aged 25 to 69 carried student debt, rising to 35.7 percent of those 25 to 29, and borrowers participate less than debt-free peers of the same age, 75.5 percent against 84.1 percent. The median balance gap between borrowers and nonborrowers peaks for workers in their 40s, at 45 percent.

Employee Fiduciary’s explainer walks through match design end to end with 2026 numbers in place, the $24,500 deferral limit, the $72,000 cap on total contributions and the $360,000 compensation limit. It covers the standard formulas and their tradeoffs, single-tier and multi-tier matches, stretch formulas that buy more deferral per match dollar, safe harbor designs, including the automatic-enrollment variety, with their vesting rules, and discretionary matches that trade predictability for flexibility. The true-up discussion is the part worth confirming with payroll; employees who max out early can miss part of the match if it is calculated paycheck by paycheck and the plan does not make a year-end adjustment. Roth matching contributions under SECURE 2.0 get a practical treatment too.

Congress made pooled employer plans possible in the SECURE Act without settling how they fit the securities laws. The “single trust” exemptions that keep benefit plans from registering with the SEC read like they were written for one employer at a time, because they were. A new Carlton Fields explainer walks through [the SEC staff statement](https://www.sec.gov/newsroom/speeches-statements/im-staff-statement-pooled-employer-plans-050426) from May that addressed the mismatch: the staff will not object if a PEP treats itself as a single-employer plan for those exemptions. The practical payoff concerns collective investment trusts. The staff also described how CITs can accept PEPs covering self-employed participants under Rule 180, and the required financial sophistication can be assessed at the pooled plan provider level. The statement does not change the law, but it gives providers a clearer route to offering lower-cost CITs alongside mutual funds.

Just when retirement plan sponsors thought disclosure rules couldn’t get any more convoluted, the Department of Labor has offered temporary relief on SECURE 2.0’s paper statement requirements.

What larger retirement plan sponsors stand to gain and give up in a pooled employer plan created under the SECURE Act of 2019.

Hobbs, Esq. Britney, a retired singer and superstar, owns and operates Lucky Records (the “Company”), a record company in Los Angeles with 44 employees. The Company sponsors the Lucky Records 401(k) Profit Sharing Plan (the “PS Plan”) to help its employees save for retirement.

CEOs send letter to Senate Banking Committee asking for movement on House-passed bipartisan bill that would finally permit access intended by SECURE 2.0