Make-up for promised employer-matched IRA contributions?

I started at my job in Colorado at a small business in November of last year. I am the owner's EA, and I do a little of everything. My past positions I have had some minor HR experience, mostly payroll/time tracking/record keeping/PEO admin. I have extremely limited knowledge on retirement accounts on either employee or employer side, and my boss knows this. 

When my boss set up a Roth IRA (Vestwell Colorado SecureSavings) at the end of 2024, he told current employees and employees he hired after, that we were matching 3% of all employee contributions to their IRA. Maybe he thought it was happening automatically, but it never did because it was the kind of IRA that didn't allow employer contributions. I don't think he knew any of this until I had an employee ask me why their contributions weren't being matched, so I looked into it.

We recently switched over to a Human Interest 401k Safe Harbor plan, and my boss asked me if we can make up for all the missed IRA employer contributions in late 2024/2025/early 2026 by adding them to employee plans off-cycle. That isn't possible, so I am trying to figure out other options we have.

• We cannot add off-cycle contributions.

• We cannot edit employee matching percentages (his idea was to change the percentages until the funds were equal to our missing match).

• Our account manager at HI said an option is to use a "Profit Sharing" feature of our plan, but would not be able to do so until early 2027.

He doesn't want to just cut checks, but I'm not sure that's the way to do it anyway. Like I said, I have very little knowledge of retirement accounts and am feeling 100% lost, hence my username. Any ideas on this?

Profit sharing is likely the best option, and yes, amounts allocated for tax year 2026 would not be deposited until 2027 after 2026 is over and everyone's compensation is known. However, whether this can fix everyone depends on how the profit sharing provision is structured (plan might even need to be amended to provide) and for who and how much needs to be contributed. If anyone is a highly compensated employee (HCE) by IRS definition, such person may need to be restricted. Yes, this delays the fix, but it gives your consultant time to ensure proper construction of the provision and see if these "make-up" contributions can be accommodated this way and satisfy all the various IRS requirements.

Cutting checks for these, like a bonus payment, which employees could defer into the plan might work but incurs payroll taxes (FICA and Medicare). If the plan didn't have/allow special bonus-only salary deferral elections, then to defer it all people would need to change their deferral election before that payment and change back after, kind of a hassle.

Presuming your consultant knows your plan best, press him/her for guidance on this. Good luck.