BENEFITS DIGEST

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.

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.

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.