April 2026
SECURE 2.0 plan sponsor update
Regulatory and compliance roundup
New government guidance and approaching 2026 compliance deadlines for SECURE 2.0 continue to shape the landscape for retirement plans. This regulatory and compliance roundup highlights recent government updates, key amendment deadlines that may affect plan administration and fiduciary responsibilities, and Vanguard thought leadership. Vanguard is here to help you stay informed as implementation progresses and requirements continue to evolve.
Guidance on required provisions
On February 25, 2026, the Department of Labor issued a proposed regulation on the paper statement requirement seeking to update two electronic safe-harbor disclosures and bring consistency between this SECURE 2.0 provision and existing federal regulations. Comments on the guidance are accepted until April 26, 2026—60 days after the guidance was issued.
Plan amendments
After several years of legislative change and extended IRS relief, many retirement plan amendments tied to the SECURE Act (2019), the CARES Act (2020), and the SECURE 2.0 Act (2022) must be formalized in written plan documents no later than December 31, 2026, with some exceptions in place for collectively bargained plans and most governmental 457(b) plans.
Key required provisions for which amendments are due:
- Required minimum distribution (RMD) age increase
Increased the RMD age from 72 to 73 for individuals who attain age 72 after 2022.
- Reduced eligibility period for long-term part-time (LTPT) employees; expansion to 403(b) plans
Part-time employees who work at least 500 hours in each of two consecutive years starting with 2023 must be eligible to make elective deferrals to their employer’s retirement savings plan.
- Roth catch-up contributions
Requires catch-up contributions to be made as Roth contributions for participants ages 50 and older who earned more than $150,000 (indexed) in FICA wages from the employer sponsoring the plan in the previous calendar year.
- Mandatory automatic enrollment for new plans*
New plans established after December 29, 2022, must include an automatic enrollment provision of at least 3%, with an automatic increase feature up to at least 10% (but no more than 15%). Existing plans are not required to add automatic enrollment or automatic increase.
* Plan sponsors with a new plan using a custom document should check with their ERISA counsel to determine if a plan amendment is required.
Key optional provisions for which amendments are due:
- Higher catch-up contributions
Allows plans to increase the catch-up limit to $11,250 for participants ages 60–63. The limit may increase each year due to cost-of-living adjustments.
- Qualified Disaster Recovery Distribution (QDRD)
Allows distributions of up to $22,000 per disaster to those impacted by certain federally declared disasters without being subject to the 10% early withdrawal penalty. Distributions can be repaid within 3 years from the date of distribution.
- Emergency expense withdrawals (EEW)
Allows a distribution of up to $1,000 for personal or family emergency expenses. One distribution per year is allowed, and another distribution cannot be processed for 3 years unless the first distribution is repaid. Distributions may be repaid as a lump sum or through ongoing elective deferrals.
- Withdrawals for domestic abuse (WDA)
Allows a withdrawal for domestic abuse survivors in the amount of the lesser of $10,500 or 50% of the participant’s vested account balance without being subject to the 10% early withdrawal penalty. Can be repaid to a qualified plan within 3 years of the distribution.
- Self-certification for hardship withdrawals
Allows plans to permit participants to self-certify that a distribution meets the requirements for a hardship withdrawal.
- Automatic cash-out limit increase
Allows the cash-out limit for terminated employees to be increased from $5,000 to $7,000. Amounts that are $1,000 or less will be paid as a lump sum, and those greater than $1,000 up to $7,000 will be rolled over to an IRA.
- Matching contributions for student loans*
Allows plans to make matching contributions on qualified student loan payments without requiring employees to make elective deferrals.
- Autoportability service**
Allows small account cash-outs to be rolled over to an IRA at Retirement Clearinghouse (RCH). Portability Services Network will try to locate an account holder’s new employer-sponsored plan and will roll over the RCH IRA to the new employer’s plan.
* Plan sponsors should refer to their agreement with Candidly to determine if and when this provision was adopted.
** Plan sponsors should refer to their contract with RCH and the Portability Services Network to determine if and when this provision was adopted.
Plan sponsor resources
Vanguard is here to help plan sponsors feel confident they are compliant with the December 31, 2026, deadline (for most qualified retirement plans and nongovernmental 403(b) plans) to adopt amendments related to the SECURE Act, CARES Act, and SECURE 2.0. We encourage you to review the following resources related to this requirement:
This detailed article reminds plan sponsors of provisions from the SECURE Act, CARES Act, and SECURE 2.0 Act to ensure they know about what provisions their plan adopted and when formal amendments are required.
Plan amendment summary
This guide allows plan sponsors to see—provision by provision—deadlines to adopt amendments for provisions enacted as part of the SECURE Act, CARES Act, and SECURE 2.0. Please reach out to your Vanguard representative to obtain this guide.
Vanguard thought leadership
Learn about the latest developments from Washington, DC, that are shaping retirement policy and investment strategies. Vanguard’s experts break down what’s happening with policy updates, investment innovations, investor advocacy, and more.
Plan amendment deadlines
(apply regardless of plan year)
Under IRS Notice 2024-2, most qualified retirement plans and nongovernmental 403(b) plans must adopt required amendments for the SECURE Act, CARES Act, and SECURE 2.0 no later than December 31, 2026. Some plans, such as collectively bargained and governmental 457(b) plans, have extended amendment deadlines.
December 31, 2026
Qualified plans that are not a governmental or collectively bargained plan and 403(b) plans not maintained by a public school
December 31, 2028
Collectively bargained plans (i.e., union plans)
December 31, 2029
Governmental plans and 403(b) plans sponsored by a public school
The SECURE 2.0 Plan Sponsor and Consultant Resource Center offers you the latest insights and information from Vanguard.
News and thought leadership
As we acclimate to an environment where many of SECURE 2.0's new rules move from theory to practice, Vanguard remains dedicated to sharing our perspective on the required and optional provisions set to take effect in 2026 and beyond. The resources below provide detailed insight on what you can expect from required provisions coming later this year, as well as what optional provisions may be a best fit for your participants on their path to financial wellness.