As 2026 draws to a close, retirement plan sponsors have an important year-end item to review: whether their plan documents have been updated to reflect recent legislative changes.
For many private employer retirement plans, December 31, 2026 is an important amendment deadline for provisions arising under the Setting Every Community Up for Retirement Enhancement Act (SECURE Act), the Coronavirus Aid, Relief, and Economic Security Act (CARES Act), and Division T of the Consolidated Appropriations Act (SECURE 2.0). These laws affect a variety of plan provisions, including Roth employer contributions, catch-up contributions, required minimum distributions, long-term part-time employees, and new distribution options.
Now is a good time to confirm where your plan stands.
For most private employer plans, sponsors have until December 31, 2026, to update plan documents for optional SECURE or SECURE 2.0 features already implemented. Certain required changes will have later amendment deadlines established through IRS guidance. Even where later deadlines apply, plan sponsors may find it simpler to address their SECURE and SECURE 2.0 updates together rather than track multiple deadlines.
Depending on your plan document provider and service arrangements, the necessary amendments may already be complete or underway. But plan sponsors should confirm rather than assume.
Before year-end, consider confirming:
- Who is responsible for maintaining and amending your plan document;
- Which SECURE and SECURE 2.0 provisions your plan has implemented; and
- Whether the necessary amendments have been completed or are in process.
If you have questions about these changes or would like assistance reviewing your plan’s amendment status or coordinating with your service providers, Poyner Spruill’s Employee Benefits team would be happy to help.
