Automatic Enrollment under SECURE 2.0

Does anyone know the answer to the following question, or are we all waiting for guidance from the IRS?:

Scenario: A 401k plan was established effective January 1, 2023, and the client opted at the time the plan was being established to wait until January 1, 2025 to add the mandatory automatic enrollment provisions to the plan.

Question: When the plan is amended effective January 1, 2025 to add the mandatory automatic enrollment provisions to the plan, which participants must be included in the automatic enrollment provisions? Does it need to be applied to all who are plan participants as of January 1, 2025 as well as all future plan participants, or can it just be applied to those who first become participants on or after January 1, 2025?

21 hours ago, sb0828 said:

Question: When the plan is amended effective January 1, 2025 to add the mandatory automatic enrollment provisions to the plan, which participants must be included in the automatic enrollment provisions? Does it need to be applied to all who are plan participants as of January 1, 2025 as well as all future plan participants, or can it just be applied to those who first become participants on or after January 1, 2025?

It can be applied to new participants only, but if you limit coverage to new participants you don't get the 6 month deadline for corrective distributions.