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) for your PlanPremier®-Bundled workplace retirement plan. For a better understanding of these provisions, refer to SECURE 2.0 Act of 2022 ― A boost to retirement saving (PDF) or speak with your plan’s financial professional.
We’re committed to supporting key SECURE 2.0 provisions and making it as easy as possible for your plan to comply with the requirements. We’ll provide a SECURE 2.0 amendment to plans using our document services prior to the IRS extended deadline to adopt the amendment planned for 2026. The fee for the amendment is $1,250 per plan, and will include mandatory provisions and any optional provisions adopted by your plan.
Recordkeeping status for key SECURE 2.0 Act provisions
Provision |
Effective date |
Recordkeeping status |
|---|---|---|
Qualified disaster recovery distributions Section 331 (optional) |
Effective for disasters occurring 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 New options simplify hardship withdrawal administration, including summary hardships and self-certification hardship withdrawals. |
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: Please engage with your payroll provider now to ensure that they are prepared to appropriately handle employee contributions as described above for participants subject to the requirement. 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. You can use the following sample notifications to inform participants about this rule and any related changes that you’ve made to your plan:
|
Annual paper statement requirement Section 338 (mandatory) |
Plan years beginning after December 31, 2025 |
Will support in 2026 |