News & Announcements

December 2, 2025

Status of recordkeeping support for SECURE 2.0 Act provisions

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 RecordkeeperDirect® 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.

Recordkeeping status for key SECURE 2.0 Act provisions

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 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	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 60 to 63 (“super” catch-up limit) 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, and talk to your 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. You can use the following sample notifications to inform participants about this rule: Sample notice for plans with the “deemed” Roth election Sample notice for plans without Roth
Annual paper statement requirement Section 338 (mandatory)	Plan years beginning after December 31, 2025	Will support in 2026.

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