Key SECURE 2.0 Amendment Reminders for 2026

This article was written by Jesse St. Cyr, Partner, Poyner Spruill

The SECURE 2.0 Act of 2022 introduced significant changes to retirement plans, many of which have been rolled out over several years.

While plan sponsors have already implemented many of these provisions, 2026 represents a critical deadline year for required plan amendments.

Below is a quick reference guide outlining the key SECURE 2.0 amendments that must be adopted by December 31, 2026 for many retirement plans.

Eligibility & Participation Amendments

Plan sponsors should review the following participation-related requirements:

Automatic Enrollment Requirements

If you established a new 401(k) or 403(b) plan after December 29, 2022, SECURE 2.0 generally requires the plan to include:

Automatic enrollment
A specified default contribution rate
Automatic escalation provisions

These requirements apply to plan years beginning after December 31, 2024, although certain exceptions may apply.

Long-Term, Part-Time Employee Eligibility

401(k) and 403(b) plans must adopt updated plan language reflecting:

SECURE 2.0’s expanded eligibility rules for long-term, part-time employees

Contribution-Related Amendments

Several important contribution updates must be reflected in formal plan documents:

Roth Catch-Up Requirement for High Earners

Defined contribution plans that allow catch-up contributions must be amended to require:

Catch-up contributions for high earners to be made as designated Roth contributions

This requirement applies for plan years beginning after December 31, 2025.

Enhanced Catch-Up Contributions (Ages 60–63)

SECURE 2.0 allows higher catch-up contribution limits for participants ages 60–63.

Many plans have already implemented this provision
Affected plans must formally amend plan documents

Other Contribution-Related Provisions

Plans must also be amended if they allow:

Employer contributions to be made as Roth contributions
Employer matching contributions on qualified student loan repayments

Distribution-Related Amendments

SECURE 2.0 also introduced several distribution-related changes requiring plan updates.

Required Minimum Distribution (RMD) Changes

Plans must reflect the updated RMD rules:

RMD age increased from 72 to 73 beginning in 2023
RMD age will increase to 75 beginning in 2033

Additionally:

Defined contribution plans must eliminate lifetime RMDs for designated Roth accounts

Qualified Birth or Adoption Distributions (QBADs)

If your plan allows QBADs, amendments must address:

The three-year repayment limit for distributions made after December 29, 2022

Emergency & Special Distributions

Plans offering the following must adopt updated language:

Emergency personal expense distributions
Distributions for victims of domestic violence

Final Reminder for Plan Sponsors

Be sure to work closely with your plan partners—including your TPA, recordkeeper, ERISA counsel, and financial professional—to ensure that all required SECURE 2.0 amendments are formally adopted by December 31, 2026.

Note: Certain plans, such as governmental and collectively bargained plans, may be subject to later amendment deadlines.

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