If SECURE 2.0 has been sitting on your to-do list, consider this your midyear nudge.
While many plan sponsors have already operationally implemented provisions from the CARES Act, SECURE Act, and SECURE 2.0 over the past few years, there’s an important milestone ahead: By December 31, 2026, those changes must be formally documented in your plan documents.
The deadline may sound far away, but from an administrative, compliance, and audit standpoint, it’s closer than it feels.
Why Summer Is the Time to Start the Conversation
We’re in the season now where proactive planning makes all the difference. Rather than waiting until year-end, summer is the ideal time to:
- Take inventory of what’s already been implemented vs. formally adopted
- Connect with your third-party administrator (TPA) and advisors
- Identify any gaps in compliance or documentation
- Build a realistic timeline for plan amendments
This process won’t be something you want to rush in Q4. The most successful plan sponsors are the ones starting these conversations early and avoiding the last-minute scramble.
The Mandatory Provisions You Can’t Ignore
SECURE 2.0 introduced a number of required updates that must ultimately be reflected in your plan documents if they apply to your specific plan. Here are some of the key provisions we’re discussing most often with clients:
- Automatic Enrollment (Section 101)
- Requires new 401(k) and 403(b) plans (established after 12/29/2022) to automatically enroll eligible employees
- Initial deferral must be 3%–10%, increasing annually by 1% up to 10%–15%
- Effective for plan years beginning after 12/31/2024
- Increase in Required Minimum Distribution (RMD) Age (Section 107)
- Raises RMD age from 72 → 73 (2023) and eventually 75 (2033)
- Impacts timing of participant withdrawals and plan distribution compliance
- Expanded Eligibility for Part-Time Employees (Section 125)
- Reduces long-term part-time eligibility rule from 3 years to 2 years (500 hours/year)
- Expands access to retirement plans for part-time employees
- Effective for plan years beginning after 12/31/2024
- Top-Heavy Testing Changes (Section 310)
- Allows plans to exclude certain employees (e.g., underage, service thresholds) from top-heavy testing
- Helps reduce employer costs and expand participation
- Effective for plan years beginning after 12/31/2023
- Birth and Adoption Distribution Repayment Limits (Section 311)
- Imposes a 3-year limit to repay qualified birth and/or adoption distributions
- Applies retroactively and prospectively
- Mandatory if the plan offers Qualified Birth and Adoption Distributions
- Elimination of Roth RMDs (Section 325)
- Eliminates pre-death RMDs for Roth accounts in employer plans
- Aligns with Roth IRA treatment
- Effective for tax years beginning after 12/31/2023
- Group Audit Threshold Clarification (Section 345)
- Clarifies that audit requirement applies only if ≥100 participants in a group filing
- Streamlines reporting for defined contribution group filings
- Effective upon enactment
- 403(b) Hardship Rule Alignment (Section 602)
- Conforms 403(b) hardship withdrawal rules to 401(k) rules (broader access to funds)
- Effective for plan years beginning after 12/31/2023
- Mandatory only if the plan allows hardship withdrawals
- Roth Catch-Up Contribution Requirement (Section 603)
- Requires catch-up contributions to be Roth (after-tax) for higher-income participants
- Applies to employees earning over $145,000 (indexed) in the immediate prior year
- Effective for tax years beginning after 12/31/2025
Bottom line: Even if you’ve been operating under these rules already, they still need to be formally adopted.
What We’re Seeing with Optional Provisions
SECURE 2.0 also introduced a variety of optional features, many of which are designed to improve financial flexibility and participant outcomes. Several of the prominent optional features are:
- Student loan matching contributions
- Emergency savings accounts
- Emergency and hardship-related withdrawal options
- Enhanced catch-up contribution opportunities
- Roth treatment for employer contributions
- Disaster-related relief provisions
- And more
While the intent behind many of these optional provisions is strongly aligned with improving participant outcomes, we’re seeing more limited adoption in practice due to the added administrative burden.
A Simple but Important Next Step
If there’s one takeaway, it’s this: Don’t wait!
Now is the time to reconnect with your TPA and advisors, confirm what’s been implemented vs. documented, prioritize required amendments, and thoughtfully evaluate optional features.
These conversations don’t need to be complex – but they do need to happen.
Looking Ahead
The 2026 deadline will be here before we know it. Taking a proactive approach can help you stay compliant, reduce risk, and position your plan for long-term success.
Be sure to check our previous article on SECURE 2.0 deadlines to view best practices for plan sponsors: SECURE 2.0 Deadlines: What Plan Sponsors Need to Know to Stay Audit-Ready
And if you have any questions, we are here to help. Please do not hesitate to reach out to discuss your specific situation.
This material has been prepared for general, informational purposes only and is not intended to provide, and should not be relied on for, tax, legal or accounting advice. Should you require any such advice, please contact us directly. The information contained herein does not create, and your review or use of the information does not constitute, an accountant-client relationship.
