"[S]ponsors of qualified and Section 403(b) plans have until December 31, 2027, to amend their plans for the RMD changes included in the 2025 RAL. The SECURE 2.0 RMD changes that were not included in the 2024 final regulations are expected to be included in a later RAL ... The 2025 RAL also states that the final regulations issued in 2025 regarding SECURE 2.0's Roth catch-up requirement for high earners are expected to be included in the 2027 RAL. If that proves to be the case, plan sponsors will have until December 31, 2029, to amend their plans to include the Roth catch-up provisions." MORE >>
"Plan sponsors rely on providers because they cannot realistically master this level of detail themselves.... Providers who want to avoid being swept into the catch-up mess should focus less on marketing readiness and more on structural honesty. First, stop oversimplifying.... Second, document limitations clearly.... Third, help sponsors build internal processes.... Finally, resist the urge to promise protection." MORE >>
"The extended deadline applies to IRAs under Internal Revenue Code (IRC) Section 408(a), (b) and (h) as well as Simplified Employee Pension (SEP) arrangements and Savings Incentive Match Plan for Employees (SIMPLE) IRAs. It covers all amendments -- required or discretionary -- related to these laws and any associated regulations." MORE >>
"While year-end is a natural checkpoint, reassessing your retirement plan at the start of the year offers several advantages:[1] Tax efficiency ... [2] Regulatory compliance ... [3] Employee engagement ... [4] Strategic alignment." MORE >>
"For employees who are rehired in a different calendar year after separating from service ... review the FICA wages the employer (or aggregated group, if elected) paid to the employee in the calendar year preceding the year of rehire.... [If] the rehired employee did not have any FICA wages from the employer (or aggregated group, if elected) in the prior calendar year, the Roth catch-up requirement does not apply, and the employee may make catch-up contributions on a pre-tax or Roth basis according to plan terms." MORE >>
"IRS says [in Notice 2026-9] that it extended the deadline because it and the Treasury Department are still developing model language that may be IRA trustees, custodians, and issuers may use to amend an IRA for compliance with the SECURE 2.0 Act." MORE >>
"This notice provides guidance relating to amendments under section 501 of ... the SECURE 2.0 Act ... for an individual retirement arrangement (IRAs) under section 408(a), (b), or (h) of the Internal Revenue Code, an employer's SEP arrangement under section 408(k), and an employer's SIMPLE IRA plan under section 408(p). This notice provides that the Department of the Treasury and the [IRS] have extended the deadline to make certain amendments for IRAs, SEP arrangements, and SIMPLE IRA plans to December 31, 2027." MORE >>
"According to the 2023 PRRL data, 2 percent of all contributing participants made catch-up contributions, which represents 5 percent of all eligible participants. Among those participants, 24 percent earned more than $150,000. Although this group represents a small portion of all contributing participants, half of the plans received catch-up contributions from those earning over $150,000." MORE >>
"The flexibility to use either the W-2 correction method or the in-plan Roth rollover correction method is helpful, but both approaches present challenges.... The safe harbor for BRF nondiscrimination requirements may help mitigate some administrative complexities.... [O]perational challenges will require careful planning and close coordination among payroll, recordkeeping, and plan administration teams." MORE >>
10 pages. "This article provides a detailed discussion of the final regulations ... regarding the catch-up contributions for people ages 60-63 and those catch-up provisions related to Roth amounts.... While the Age 60-63 increased catch-up limit appears relatively easy to navigate, it is clear that Congress's activities in relation to Roth catch-up contributions has created quite the hornet's nest of issues." MORE >>
"Just as annual limit increases prompt plan checkups and fresh strategy conversations, SECURE 2.0's mid-year SIMPLE IRA 'off-ramp' gives advisors a timely way to help growing employers pivot into a more robust retirement plan without waiting for the next calendar year. Thanks to SECURE 2.0, employers can now replace a SIMPLE IRA mid-year with a safe harbor 401(k)." MORE >>
"SECURE 2.0 continues to dominate the landscape.... Continued monitoring of class action litigation developments against fiduciaries, and engaging in (and documenting) a strong fiduciary process.... Attention to Form 5500 filing requirements, and participation in 'DFVC' as warranted.... Consideration of developing products and features relative to offering lifetime income and alternative investments.... Monitoring of plan activities to identify and correct qualification failures." MORE >>
"This article walks through the amendment process employers should expect in 2026 to help clarify what decisions matter, which ones don’t, and when action is required." MORE >>
33 pages; rev. Jan. 2026. "What's new for 2025: Catch-up contributions.... What's new for 2026: [1] Retirement savings contributions credit.... [2] Limit on elective deferrals.... [3] Limit on annual additions." MORE >>
"The provision went into effect Dec. 29, 2025, and allows allow participants to take penalty-free withdrawals (up to $2,500 annually, indexed) from retirement plans to pay for high-quality, certified long-term care insurance premiums, though the distributions remain subject to ordinary income tax. Most plans have not added this provisions (82 percent) with only 1.5 percent already adding it and 1.5 percent adding it this year (currently adding to plan documents), though 25 percent are considering it." MORE >>
"Based on past IRS guidance, it is more than likely that an employee of either company in a statutory merger that was subject to the Roth catch-up contribution requirements of SECURE 2.0 Act prior to the statutory merger will continue to be subject to the Roth catch-up contribution requirements after the merger. Similarly, if the statutory merger occurs midyear, the employee's compensation for the year of the merger will include compensation paid by either entity." MORE >>
"A new exception from the additional 10% tax for early distributions from defined contribution plans (including 403(b) and 457(b) plans) is now available.... Section 334 of SECURE 2.0 allows in-service distributions to pay for certain LTC premium payments.... Even if the in-service distribution option is not offered, presumably a participant who has a distributable event can claim the 10% tax exception via Form 5329, though the form is not yet updated." MORE >>
"[As] they dip their toes into Roth contributions, these participants may be more interested in making additional Roth contributions or consider converting existing pre-tax accounts to Roth. Affected participants will likely continue making catch-up contributions, either because they are behind and saving a relatively large percentage of their income or because they are high earners limited by the base deferral rate[.]" MORE >>
"Group Health Plans: [1] Preventive care for 2025 and 2026 ... [2] [ACA] reporting ... [3] Mental Health Parity and Addiction Equity Act of 2008 requirements ... Retirement Plans: [1] SECURE 2.0 Act mandatory Roth catch-up contributions for high earners -- January 1, 2026 ... [2] Plan amendment deadlines." MORE >>
"The 2026 Roth catch-up rules require coordinated action across plan documents, payroll systems, and recordkeeping platforms. Employers should confirm that payroll can identify HPPs based on prior-year FICA wages, ensure timely Roth elections, and implement appropriate correction procedures. Early planning and clear participant communication will be essential to minimizing operational risk and maintaining compliance." MORE >>
"[As] the deadline for Roth treatment of catch-up contributions nears ... organizations are focused on plan changes and processes for implementation. Seventy percent of plan sponsors are focused on that and the Jan 1, 2026, good faith implementation deadline. Sixty percent of respondents stated their priority next year is participant education, while nearly 30% are focused on other SECURE Act provisions[.]" MORE >>
"Plan sponsors should be collaborating with their payroll vendors and recordkeepers to understand how mandatory Roth catch-up contributions will be processed for high wage earners ... [If] at least one applicable retirement plan within a controlled group permits super catch-up contributions, all controlled group retirement plans must also permit super catch-up contributions.... By February 16, 2026, each HIPAA covered entity and business associate must update its Notice of Privacy Practices (NPP) ... Some section 409A corrections under Notice 2008-113 must be completed by year-end, making now the ideal time to identify and finalize correction of any lingering errors." MORE >>
"As we look ahead to 2026, plan sponsors face a shifting landscape of regulation, fiduciary risk and opportunity, evolving plan design, and rapidly changing participant expectations. In many respects, this moment represents a continuation of change -- but with unusual force and urgency.... [P]lan sponsors will need to be proactive." MORE >>
"[S]everal new laws will have significant implications for qualified retirement plans, including amendments that must be made by the 2026 plan year.... The recently enacted One Big Beautiful Bill Act (OBBBA) also contains provisions impacting health and welfare plans, many of which are effective beginning January 1, 2026.... [M]any cost-of-living adjustments that are mandated by law will impact retirement plans and health and welfare plans in 2026.... [This article provides] plan sponsors with summaries of the key action items they should be considering, now and in the future[.]" MORE >>
"The Final Catch-up Regulations largely confirmed what we were expecting, by clarifying Highly Paid Individual (HPI) determinations, employer aggregation, and correction mechanics. However, there were some twists thrown in that plan sponsors should be aware of as 2026 approaches. The language was confusing, but this post will break it down in simple terms with simple dates." MORE >>
