The Setting Every Community Up for Retirement Enhancement (SECURE) 2.0 Act of 2022 brings a fresh round of deadlines affecting workplace retirement plans in 2026. Here’s what employers need to know to prioritize for the year accordingly.

Background and Quick Checklist

As a follow-up to the SECURE Act passed in 2019, Congress passed the SECURE 2.0 Act in December 2022, aiming to provide even more retirement options for American workers. The latest legislation includes a significant amount of provisions impacting retirement plan providers and employees, with many of them going into effect for the first time in 2026. On the list of priorities for this year:

• Activate a Roth feature and ensure it’s ready for mandatory catch‑up contributions.
• Determine if you will allow participants ages 60 to63 to make “super” catch-up contributions.
• Review 2026 and prior years’ SECURE 2.0 mandatory and options provision to be incorporated into the written plan document by the Dec. 31, 2026, deadline.
• Prepare for long‑term, part‑time (LTPT) employee eligibility expansion.
• Coordinate with payroll on new reporting and withholding requirements.
• Communicate changes to employees in clear, timely terms.

A Deeper Dive Into 2026 SECURE 2.0 Deadlines

Roth Feature Requirement for Plans With Catch‑Up Contributions 

Plans allowing catch‑up contributions must also offer a Roth feature in 2026 for your plan to stay compliant. High earners (more than $150,000 in FICA wages in 2025) aged 50 and older must make catch-up contributions on a Roth basis beginning this year. Also to note in 2026, employees ages 60 to 63 are allowed “super” catch‑up Roth contributions at an extra $3,750 for 2026 (capped at $11,250, which includes the regular $7,500 catch-up). Employers will need to think about plan document, payroll and recordkeeping updates to ensure they’re ready to apply the new treatment for these earners.

Dec. 31, 2026, Plan Amendment Deadline

Written plan amendments must be formally adopted at year-end. That means being on the lookout for notifications from plan providers, evaluating the optional and required provisions, and determining which SECURE 2.0 provisions must be incorporated into the written plan document.

Broadened LTPT Worker Eligibility Rules

Beginning in 2026, retirement plan access for LTPT employees significantly expands:

• Service requirements drop from three years to two for employees who work at least 500 hours a year.
• Coverage in 2026 expands from 401(k) plans to also include certain ERISA‑covered 403(b) plans.

Employers will need to ensure tracking systems are set to capture LTPT worker hours and be prepared to accommodate elective deferrals for both 401(k) and ERISA‑covered 403(b) plans.

Looking Beyond 2026

Preparation for 2027 IRS Catch‑Up Contribution Regulations 

By year-end 2026, employers should be prepared for clarifications going into effect in 2027 as part of IRS final regulations on Roth catch‑ups:

• Wage aggregation rules (understanding how the IRS defines and aggregates compensation that triggers mandatory catch-ups).
• Guidance on handling compliance corrections (updating your procedures for fixing errors).
• Rules for deemed Roth elections (navigating employee elections or lack thereof).

Deadline Extension for IRA/SEP/SIMPLE Plans

The IRS has extended the deadline to amend individual retirement accounts (IRAs), Simplified Employee Pension (SEP) plans and Savings Incentive Match Plan for Employees (SIMPLE) plans to at least Dec. 31, 2027, with the possibility of additional extensions.

Deadline Extensions for Governmental and Collectively Bargained Plans 

Employers have until Dec. 31, 2028, to implement required amendments to Collectively Bargained Plans (CBPs) and until Dec. 31, 2029, for governmental plans.

Act Now for a Smooth Transition

Now is the time to begin planning, communicating and coordinating operationally for these 2026 changes. Our employee benefit plan pros stand ready to help you navigate SECURE 2.0 with clarity and confidence.