SECURE 2.0 Plan Amendments Due by Year-End
SECURE 2.0 Plan Amendments Due by Year-End
Retirement Qualified retirement plans must adopt written amendments reflecting SECURE 2.0 changes by December 31, 2026. This deadline is mandatory for all plans, including those plans that opted out of the optional provisions. These plans must still be amended for mandatory changes, such as the increase in the required minimum distribution age. Plans covered by collective bargaining agreements have until December 31, 2028, while governmental plans have until December 31, 2029.
The amendment formalizes changes that many plans have already put into operation since each provision took effect. Key areas that plan sponsors and their advisors should review together include auto-enrollment and escalation rules, catch-up contribution changes, Roth designation requirements, long-term part-time employee eligibility, emergency and hardship distribution updates, and the updated cash-out threshold.
Participant Notice Requirements
ERISA plans must provide participants with a Summary of Material Modifications to participants within 210 days after the close of the plan year in which the amendment is adopted. For calendar-year plans amending in 2026, that deadline is July 29, 2027.
Next Steps
Plan sponsors should work with their advisors and legal counsel to confirm which provisions apply, verify that current plan operations match the amended terms, and complete the required amendment before year-end.
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