With 2026 around the corner, plan sponsors should be aware of and prepared for the implementation of several SECURE 2.0 Act-related provisions. The SECURE 2.0 Act—Setting Every Community Up for Retirement Enhancement Act of 2019— was signed into law in December 2022, expanding upon the SECURE Act of 2019.
Here’s an overview of the SECURE Act provision timeline highlights that will be referenced throughout:
2019
2025
2026
Long-Term, Part-Time (LTPT) Workers: 401(k) plans must allow employees who worked at least 500 hours for three consecutive years to make elective deferrals beginning with the first plan year on or after January 1, 2024.
LTPT Workers: The LTPT rule expanded in SECURE 2.0 to include ERISA-covered 403(b) plans. In addition, the three-year trigger was reduced to two years.
The general amendment deadline for qualified plans is December 31, 2026. (Collectively Bargained Plans: December 31, 2028. Governmental Plans: December 31, 2029.)
Roth Catch-Up Contributions: For plans allowing catch-ups, catch-up contributions must be made on a Roth basis for those with incomes over $150,000 in 2025.
Plan Amendment Deadline
Under the original SECURE 2.0 Act, plans would have had to adopt amendments to come into compliance with the mandatory provisions of the legislation by the end of 2024. The IRS pushed that out even further for most plans (with the exception of governmental plans and plans that are subject to collective bargaining agreements) until December 31, 2026.
Catch-Up Contributions as Roth for Certain High Earners1
Starting in 2026, those aged 50 or older who earned over $150,000 in FICA wages2 in 2025 (indexed annually for inflation) from the same employer, are required to make any catch-up contributions on an after-tax Roth basis.
The SECURE 2.0 Act also eliminated the requirement for required minimum distributions (RMDs) from Roth accounts within employer-sponsored plans beginning in 2024.
Long-Term, Part-Time Worker Eligibility
Prior to the enactment of the SECURE Act of 2019, 401(k) plans were required to offer coverage to all employees age 21 and older who worked at least 1,000 hours in one year. Beginning with the first plan year on or after January 1, 2024, the act changed that rule for 401(k) plans to require that all employees who worked at least 500 hours for three consecutive years to be given the opportunity to make elective deferrals to the plan.
The SECURE 2.0 Act broadened the LTPT provision by lowering the number of years for part-time workers to be eligible to two years and expanding coverage to 403(b) plans subject to ERISA.
Steven Ortiz is an Vice President of National Accounts at Mutual of America. If you have questions, please contact [email protected].
1 Catch-up contributions as Roth applies to 401(k), 403(b) and governmental 457(b) plans.
2 Federal Insurance Contributions Act (FICA) wage refers to the portion of an employee’s earnings subject to Social Security and Medicare taxes.
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