SECURE & SECURE 2.0 Deadlines: Is Your Retirement Plan Ready?
The SECURE Act and SECURE 2.0 Act introduced sweeping changes to retirement plans, creating additional administrative responsibilities for employers sponsoring qualified retirement plans. While many organizations have already implemented these changes operationally, a critical deadline is now approaching: most non-governmental, non-collectively bargained qualified retirement plans must formally adopt required plan amendments by December 31, 2026.
For plan sponsors, this is more than a documentation exercise. Failure to properly amend plan documents can jeopardize the plan’s tax-qualified status.
Key SECURE and SECURE 2.0 Provisions Affecting Employers
Many plan sponsors have already experienced operational impacts from SECURE-related changes, particularly as new employee eligibility and contribution rules have taken effect.
Some of the most significant provisions requiring review and possible amendment include:
Long-Term Part-Time Employee Eligibility
The original SECURE Act required eligible long-term part-time employees to be permitted to participate in 401(k) plans for deferral purposes only, after completing three consecutive years during which they work at least 500 hours. SECURE 2.0 reduced that requirement to two consecutive years beginning in 2025.
For employers with variable-hour workforces, these provisions may require enhanced tracking and payroll coordination.
Required Minimum Distribution Changes
The legislation increased the age for required minimum distributions (RMDs), requiring plan administrators to update processes and participant communications accordingly.
Automatic Enrollment Requirements
Certain new 401(k) and 403(b) plans established after December 29, 2022 are now subject to mandatory automatic enrollment and automatic escalation provisions, unless an exception applies.
Catch-Up Contribution and Roth Provisions
SECURE 2.0 introduced several optional and mandatory Roth-related provisions, including a requirement that catch-up contributions for certain high-income participants be made on a Roth basis beginning in 2026.
Because some provisions are optional while others are mandatory, plan sponsors should carefully evaluate which changes have been adopted operationally and ensure plan documents accurately reflect those decisions.
How CSH Can Help With SECURE and SECURE 2.0
For more than four decades, CSH’s Qualified Plan Administration & Consulting team has helped organizations navigate the complexities of retirement plan compliance, administration, and strategic design.
Our professionals focus exclusively on employee benefit plans year-round, providing tailored support for 401(k), 403(b), defined benefit, and other qualified retirement plans. As the SECURE and SECURE 2.0 amendment deadlines approach, now is the time to evaluate whether your plan documents and operational practices are fully aligned.
Learn more about CSH’s Qualified Plan Administration & Consulting services and how we can help your organization remain compliant and minimize risk.
Written by: Kimberly Lennon
