The SECURE 2.0 Act marked a significant step toward enabling more small business owners and employees to pursue retirement stability.
Outlined below is the status of our recordkeeping support for some key SECURE 2.0 provisions (sections). You can share this information with your clients ― whether they have an existing retirement plan or they’re considering starting one ― to help them take advantage of the benefits from this legislation.
For a better understanding of these provisions, including our perspective on the potential impacts, refer to SECURE 2.0 ― More of a good thing (PDF).
Provision |
Effective date |
Recordkeeping status |
|---|---|---|
Qualified disaster recovery distributions Section 331 (optional) |
Effective for disasters occuring on or after January 26, 2021 |
Now supported |
Employer Roth contribution option Section 604 (optional) |
Effective for contributions made after December 29, 2022 |
Intend to support by 2027 We’re evaluating solutions based on IRS guidance. |
Terminal illness early distribution penalty tax exception Section 326 (optional) |
Distributions made after December 29, 2022 |
Now supported |
Option to reduce notices to unenrolled employees Section 320 (optional) |
Plan years beginning after December 31, 2022 |
Now supported Our automated notice delivery process incorporates this notice type. |
Relaxed required minimum distribution (RMD) rules ― age and penalty adjustments Section 107 (mandatory) |
Effective for RMDs required to be made after 2022 for individuals who turn age 73 after December 31, 2022 |
Now supported |
Self-certification for hardship withdrawals Section 312 (optional) |
Plan years beginning in 2023 |
Now supported |
Pension-linked emergency savings accounts (PLESA) Section 127 (optional) |
Plan years beginning after December 31, 2023 |
Evaluating We’re monitoring the demand for in-plan emergency savings accounts. Our early research and surveys indicate that there is not a high level of interest. |
Hardship distribution change for 403(b) plans Section 602 (optional) |
Plan years beginning after December 31, 2023 |
Now supported We support hardship distributions from earnings on elective deferrals and from qualified non-elective contributions and qualified matching contributions, as well as earnings from these sources. |
Higher dollar limit for mandatory distributions Section 304 (optional) |
Distributions made after December 31, 2023 |
Now supported |
Domestic abuse distributions Section 314 (optional) |
Distributions made after December 31, 2023 |
Now supported |
Distributions for certain emergency expenses Section 115 (optional) |
Distributions made after December 31, 2023 |
Intend to support in early 2026 We’re evaluating solutions based on IRS guidance. |
RMD treatment of Roth amounts ― Roth balance exclusion Section 325 (mandatory) |
Taxable years beginning after December 31, 2023, but not to distributions which are required with respect to years beginning before January 1, 2024, but are permitted to be paid after such date |
Now supported
|
Student loan payments as elective deferrals Section 110 (optional) |
Plan years beginning after December 31, 2023 |
Under evaluation We’re evaluating what’s needed to facilitate student loan matching. Our existing functionality allows plan sponsors to remit matching contributions when they independently verify that student loan payments have been made. |
Required automatic enrollment and auto escalation Section 101 (mandatory) |
Plan years beginning after December 31, 2024 |
Now supported |
Wider plan eligibility for part-time workers Section 125 (mandatory) |
Plan years beginning after December 31, 2024 |
Now supported Note: This provision doesn’t supersede SECURE 1.0’s eligibility rules for 401(k) plans, so workers may qualify for plan eligibility under the three-year rule as soon as 2024 or the two-year rule in 2025. |
Higher catch-up contribution limit for ages Section 109 (optional) |
Taxable years beginning after December 31, 2024 |
Now supported |
Required Roth catch-up contributions for high-income earners Section 603 (mandatory) |
Taxable years beginning after 2025 |
Will support in 2026. For plans that allow Roth contributions — We are updating participant deferral election forms and the online experience to apply the “deemed” election approach based on recently published IRS final regulations. Employee contributions for participants subject to the Roth catch-up requirement will be treated as after-tax Roth contributions once their pretax contributions reach a plan limit, unless they elect at the time a limit is reached to stop contributions. For plans that do not allow Roth contributions — We are updating participant deferral election forms and the online experience to communicate that participants subject to the requirement cannot make any catch-up contributions and their elective deferral contributions will stop when a limit is reached. Important: We encourage your clients to engage with their payroll provider now to ensure that they are prepared to appropriately handle employee contributions as described above for participants subject to the requirement. Clients who use a third-party administrator should talk to their TPA about any necessary plan document amendments. Also, there’s a new data element on the website that identifies which participants are subject to the Roth catch-up requirements, and the data needs to be provided annually. We have provided sample notices to sponsors that they can use to inform participants about changes related to this rule. Starting in 2026, we’ll offer warnings during payroll processing and on the participant website for participants age 50+ who are high earners and reach the 402(g) contribution limit. |
Annual paper statement requirement Section 338 (mandatory) |
Plan years beginning after December 31, 2025 |
Will support in 2026. |
Provision |
Effective date |
Recordkeeping status |
|---|---|---|
Qualified disaster recovery distributions Section 331 (optional) |
Effective for disasters occuring on or after January 26, 2021 |
Now supported |
Employer Roth contribution option Section 604 (optional) |
Effective for contributions made after December 29, 2022 |
Intend to support by 2027 We’re evaluating solutions based on IRS guidance. |
Terminal illness early distribution penalty tax exception Section 326 (optional) |
Distributions made after December 29, 2022 |
Intend to support in 2026 |
Option to reduce notices to unenrolled employees Section 320 (optional) |
Plan years beginning after December 31, 2022 |
Evaluating We're monitoring demand for this notice type. |
Relaxed required minimum distribution (RMD) rules ― increased age triggering required beginning date Section 107 (mandatory) |
Effective for RMDs required to be made after 2022 for individuals who turn age 73 after December 31, 2022 |
Now supported |
Self-certification for hardship withdrawals Section 312 (optional) |
Plan years beginning in 2023 |
Intend to support in late 2026 |
Pension-linked emergency savings accounts (PLESA) Section 127 (optional) |
Plan years beginning after December 31, 2023 |
Evaluating We’re monitoring the demand for in-plan emergency savings accounts. Our early research and surveys indicate that there is not a high level of interest. |
Hardship distribution change for 403(b) plans Section 602 (optional) |
Plan years beginning after December 31, 2023 |
Now supported We support hardship distributions from earnings on elective deferrals and from qualified non-elective contributions and qualified matching contributions, as well as earnings from these sources. |
Domestic abuse distribution Section 314 (optional) |
Distributions made after December 31, 2023 |
Now supported |
Distribution for certain emergency expenses Section 115 (optional) |
Distributions made after December 31, 2023 |
Now supported |
Higher dollar limit for mandatory distributions Section 304 (optional) |
Distributions made after December 31, 2023 |
Now supported We've updated our Automatic IRA agreement to reflect the higher limit. |
RMD treatment of Roth amounts ― Roth balance exclusion Section 325 (mandatory) |
Taxable years beginning after December 31, 2023, but not to distributions which are required with respect to years beginning before January 1, 2024, but are permitted to be paid after such date |
Now supported |
Student loan payments as elective deferrals Section 110 (optional) |
Plan years beginning after December 31, 2023 |
Under evaluation We’re evaluating what’s needed to facilitate student loan matching. Our existing functionality allows plan sponsors to remit matching contributions when they independently verify that student loan payments have been made. |
Required automatic enrollment and auto escalation Section 101 (mandatory) |
Plan years beginning after December 31, 2024 |
Now supported |
Wider plan eligibility for part-time workers Section 125 (mandatory) |
Plan years beginning after December 31, 2024 |
Now supported
|
Higher catch-up contribution limit for ages Section 109 (optional) |
Taxable years beginning after December 31, 2024 |
Now supported |
Required Roth catch-up contributions for high-income earners Section 603 (mandatory) |
Taxable years beginning after 2025 |
Will support in 2026 For plans that allow Roth contributions — We are updating participant deferral election forms and the online experience to apply the “deemed” election approach based on recently published IRS final regulations. Employee contributions for participants subject to the Roth catch-up requirement will be treated as after-tax Roth contributions once their pretax contributions reach a plan limit, unless they elect at the time a limit is reached to stop contributions. For plans that do not allow Roth contributions — We are updating participant deferral election forms and the online experience to communicate that participants subject to the requirement cannot make any catch-up contributions and their elective deferral contributions will stop when a limit is reached. Important: We encourage your clients to engage with their payroll provider now to ensure that they are prepared to appropriately handle employee contributions as described above for participants subject to the requirement and to talk to their third-party administrator about any necessary plan document amendments. Also, there’s a new data element on the website that identifies which participants are subject to the Roth catch-up requirements, and the data needs to be provided annually. We have provided sample notices to sponsors that they can use to inform participants about changes related to this rule. |
Annual paper statement requirement Section 338 (mandatory) |
Plan years beginning after December 31, 2025 |
Will support in 2026 |
Provision |
Effective date |
Recordkeeping status |
|---|---|---|
Relaxed required minimum distribution (RMD) rules Section 107 (mandatory) |
Effective for RMDs required to be made after 2022 for individuals who turn age 73 after December 31, 2022 |
Now supported |
Roth ― Employee deferrals Section 601 (optional) |
Taxable years beginning after December 31, 2022 |
Now supported for SIMPLE IRA and SIMPLE IRA Plus In progress for SEP IRAs. We’re monitoring demand and evaluating solutions. |
Roth ― Employer contributions Section 601 (optional) |
Taxable years beginning after December 31, 2022 |
Intend to support by 2027 for SIMPLE IRA Plus We're monitoring demand for SIMPLE IRA and SEP IRA solutions. |
SIMPLE IRA contribution limit changes Section 117 (mandatory) |
Taxable years beginning after December 31, 2023 |
Now supported |
SIMPLE IRA non-elective employer contributions Section 116 (optional) |
Taxable years beginning after December 31, 2023 |
Now supported |
Replace SIMPLE IRA w/ Safe Harbor 401(k) plans during the year Section 332 |
Taxable years beginning after December 31, 2023 |
Now supported |
Student loans matching contributions Section 110 (optional) |
Taxable years beginning after December 31, 2023 |
Under evaluation We're evaluating what's needed to facilitate student loan matching. Our existing functionality allows plan sponsors to remit matching contributions when they independently verify that student loan payments have been made. |
Higher catch-up contribution limit for ages Section 109 (optional) |
Taxable years beginning after December 31, 2024 |
Now supported |