EACA Mandate and QACA

I have a question on implementing a new start up QACA - does the plan have to follow the SECURE 2.0 EACA mandate of a deferral minimum of 3% and escalate up to 10 or 15%? Or, can the QACA follow the QACA rules of 3% minimum and escalate up to a 6% required maximum? Thank you!

If a plan is subject to mandatory auto enrollment, you have to satisfy all the requirements for MAE in S2.0.  

Consider also that some plan sponsors seek to meet § 414A’s tax-qualification condition (if it applies) by setting both the initial and the ending default elective-deferral percentage at 10%.

I.R.C. (26 U.S.C.) § 414A(b)(3)(A) http://uscode.house.gov/view.xhtml?req=(title:26%20section:414A%20edition:prelim)%20OR%20(granuleid:USC-prelim-title26-section414A)&f=treesort&edition=prelim&num=0&jumpTo=true

This is not advice to anyone.

Thank you both! I remember trying to get QACA's to set the minimum at 6%. So now it would have to be 10%.

Internal Revenue Code § 414A(b)(3)(A) does not command an initial default elective-deferral percentage of 10%; rather, it permits the initial percentage to be as high as 10%.

This is not advice to anyone.

Yes, but to avoid the escalator, you may elect an initial percent of 10.

if an EACA plan was set up with initial percent of 10%, can it later be amended to 5% with 1% increase annually?  This would be adopted prior to the beginning of the plan year.  I believe this would apply to all new hires or rehires.  Would it affect those that were auto enrolled at 10%?

I think it depends how you word the amendment whether it applies to future participants only or future and current participants, but I think you could do it with proper timing and employee notices.