Qualified retirement plans must adopt written amendments for SECURE 2.0 changes by December 31, 2026.
The deadline applies broadly, and even plans that elected no optional provisions must amend for mandatory changes like the increase in the required minimum distribution age.
Collectively bargained plans have until December 31, 2028, and governmental plans until December 31, 2029.
The amendment formalizes changes that many plans have already been administering operationally since each provision took effect. Topics plan sponsors and their advisors should review together include auto-enrollment and escalation rules, catch-up contribution changes, Roth designation requirements, long-term part-time employee eligibility, emergency and hardship distribution updates, and the updated cashout threshold.
Participant Notice Requirements
ERISA plans must also provide a Summary of Material Modifications to participants within 210 days after the close of the plan year in which the amendment is adopted. For calendar-year plans amending in 2026, that deadline is July 29, 2027.
Next Steps
Now is the time for plan sponsors to sit down with their advisor and legal counsel to confirm which provisions apply, verify that current plan operations match the amended terms, and execute the amendment before year-end.
