EACA and Auto Escalation

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Employer has an EACA plan and auto enrolls participants at 4%. They now what to add auto escalation at 1% up to 10%. Question -  Since this is an EACA Plan, is the employer prohibited  ( regulatory restriction vs document restriction) from including the  participants who made an affirmative election in the auto escalation?

For example Jane defers 5% of pay - can she be included in the auto escalation annually? Realize she can decline the auto escalation during the notice period.