401(k) Account Login
Login Options
For many retirement plan sponsors, December 31, 2026 marks an important compliance deadline. By year-end, most private-sector retirement plans must formally amend their plan documents to reflect applicable provisions of the SECURE 2.0 Act. While many sponsors have already implemented the law’s operational changes as required, updating the plan document is the final step in bringing the plan into compliance.
Why the Deadline Matters
The amendment deadline does not change when SECURE 2.0’s provisions became effective. Many provisions took effect in 2023, 2024, and 2025, meaning plan sponsors were generally expected to administer their plans in accordance with the law as those provisions became effective. The upcoming deadline ensures that written plan documents accurately reflect current plan operations.
Although the deadline is still several months away, waiting until the end of the year may not be the best strategy. Recordkeepers, third-party administrators (TPAs), document providers, and ERISA counsel are expected to experience an increase in amendment requests as the deadline approaches. Beginning the process early can help avoid last-minute delays and provide sufficient time for document review, internal approvals, and execution before year-end.
Review Your Plan and Coordinate with Service Providers
Although SECURE 2.0 includes more than 90 retirement-related provisions, only a relatively small number require employer action or elections. Some changes are mandatory, while others are optional features employers may choose to adopt based on their workforce, benefits philosophy, and plan objectives. As a result, each employer’s amendment package will be unique, reflecting the provisions that apply and any optional features the employer has chosen to adopt. Plan sponsors should also confirm that their plan documents accurately reflect how the plan has been administered since SECURE 2.0’s provisions became effective.
For example, some employers have elected to offer matching contributions based on employees’ qualified student loan payments, while others have added expanded Roth features or other optional plan enhancements. Any provisions implemented operationally should be reflected in the plan document.
To help ensure timely compliance, plan sponsors should consider taking the following five steps:
- Confirm which SECURE 2.0 provisions apply to the plan and verify they have been administered correctly.
- Identify any optional provisions that have been implemented and ensure they are included in the amendment package.
- Coordinate with your recordkeeper, TPA, payroll provider, document provider, and ERISA counsel to understand the amendment timeline and documentation requirements.
- Review participant communications and administrative procedures to ensure they remain consistent with current plan operations.
- Build sufficient time into your schedule for board, retirement plan committee, or other required corporate approvals before adopting the amendments.
Use the Deadline as an Opportunity
The amendment process also presents a valuable opportunity to step back and evaluate your retirement plan. Employers that have not yet adopted optional SECURE 2.0 provisions may wish to consider whether features such as student loan matching contributions, expanded Roth options, or other plan enhancements could strengthen their benefits package, improve employee financial wellness, and support recruitment and retention efforts.
While plan amendments may feel like a paperwork exercise, they are an important part of maintaining a compliant, tax-qualified retirement plan. IRS guidance generally requires most private-sector plans to adopt SECURE 2.0 amendments by December 31, 2026, while certain plans, including governmental plans, have later deadlines. Failure to timely adopt required plan amendments may jeopardize a plan’s tax-qualified status, making it important for sponsors to complete the process before the applicable deadline.
Take Action Now
With the December 31, 2026, deadline approaching, now is the time to begin working with your recordkeeper, TPA, document provider, payroll provider, and ERISA counsel to complete any required amendments. Starting the amendment process now can help avoid a year-end rush, reduce the risk of compliance issues, and ensure your retirement plan documentation accurately reflects how your plan operates today. If you have questions about your amendment requirements, please do not hesitate to contact us.