Why it matters 

In 2026, SECURE 2.0 changes directly impact how retirement plans operate day to day. Some plan sponsors are finding that their processes, plan terms, payroll coding, recordkeeper setup, and eligibility/contributions don’t quite line up with the new provisions. When these don’t match, sponsors face participant confusion, correction costs, and potential audit findings. Waiting until deadlines are near increases the chance of administrative errors, fiduciary exposure, and employee confusion at a time when expectations around retirement benefits are only growing.

Key SECURE 2.0 Provisions to Monitor in 2026

1. Plan Amendments due by December 31, 2026

• Although many provisions of the SECURE 2.0 Act have been operationally effective over the past several years, plan sponsors should not overlook a critical compliance milestone: most retirement plans must formally adopt SECURE 2.0 plan amendments no later than December 31, 2026.
• If not already completed , now is the best time for a full compliance review and coordination with your plan advisor, recordkeeper and legal counsel to ensure a smooth amendment process.
• It is important to note that plans must already be operating in accordance with SECURE 2.0, even if amendments have not yet been signed.
• This deadline generally applies to 401(k) and 403(b) plans

2. Long-Term Part-Time (LTPT) employee eligibility

The LTPT rules began under SECURE 1.0 (SECURE Act of 2019) and were expanded under SECURE 2.0. Under SECURE 1.0, 401(k) plans generally had to allow employees to make elective deferrals once they reached age 21 and completed 500 hours in three consecutive 12-month periods. SECURE 2.0 shortened the requirement to two consecutive 12‑month periods and extended the framework to ERISA-covered 403(b) plans. Though implemented in 2024 and 2025, the LTPT rules could bring some administrative issues for plan sponsors in 2026. 

Key action items for 2026

• Be sure to track hours for part-time employees with enough precision to identify LTPT eligibility.
• Revising plan documents and participant communications
• Preparing for an increase in eligible participants and enrollment activity

3. Roth catch-up contributions: mandatory for high earners

One of the most anticipated SECURE 2.0 provisions required implementation has been delayed to take  effect January 1, 2027: employees whose prior-year wages (2026 wages) exceed a specified indexed FICA threshold must make catch-up contributions on a Roth (after-tax) basis.

Key action items for 2026 in preparation for the effective date:

If your plan has participants required to make Roth catch-up contributions, make sure you can:

• Identify which employees are impacted
• Set up catch-up contributions as Roth (after-tax) for those employees
• Send the correct contribution codes to your recordkeeper
• Ensure participant statements and reports reflect the proper treatment

4. Saver’s Match

While the Saver’s Match (effective 2027) is not administered by plan sponsors in the same way as an employer match, it will still impact participant expectations and questions. Using 2026 to prepare can help avoid confusion and ensure consistent messaging.

Key action items for 2026

To get ahead of the Saver’s Match, make sure you can:

• Incorporate it into your participant education strategy
• Coordinate with your recordkeeper to ensure messaging is aligned
• Prepare clear employee communications explaining how it works
• Train HR and benefits teams to handle common questions

5. Plan document restatements + operational compliance

By 2026, many compliance issues stem from plans being operated differently than what the document says. Aligning day-to-day operations with plan terms is critical to avoiding errors and corrections.

Key action items for 2026

To keep your plan aligned and compliant, make sure you can:

• Review plan operations against the document (eligibility, entry dates, compensation, contributions, and exclusions)
• Identify and correct any gaps between how the plan is written and how it’s administered
• Document all corrections and update procedures to prevent repeat issues
• Track required amendments and restatements, with clear ownership and deadlines

6. Governance and Controls

In 2026, one of the most effective ways to reduce risk is demonstrating that your plan is operating consistently. Clear ownership, defined processes, and regular oversight can help prevent small issues from turning into costly corrections or audit findings.

Key action items for 2026

To strengthen governance and maintain consistent operations, make sure you can:

• Define clear ownership for key processes (payroll feeds, eligibility reviews, vendor changes, and error handling)
• Implement a regular review process, such as a quarterly plan operations checklist
• Reconcile payroll and recordkeeper data each pay period to catch discrepancies early
• Maintain a simple log of operational errors and how they were resolved