The SECURE 2.0 plan amendment deadline is December 31, 2026. 

Plan sponsors have had SECURE 2.0 on their radar for several years. Now the paperwork is finally catching up. For most nongovernmental tax-qualified retirement plans—including 401(k), profit-sharing and defined benefit plans—the amendment deadline is December 31, 2026. That does not mean plans could wait until 2026 to follow the new rules; they should already have been operating in compliance as each provision became effective. The year-end deadline is the time to make sure the written plan document matches what has actually been happening. 

Among the many provisions that should be reviewed are: 

• Mandatory — Long-term, part-time employees: Update 401(k) eligibility to reflect SECURE 2.0’s reduction from three consecutive years with at least 500 hours to two consecutive years.
• Mandatory — Required minimum distributions: Update the plan for the increase in the RMD starting age from 72 to 73, with a later increase to age 75.
• Discretionary — Small-balance cash-outs: Decide whether to increase the involuntary cash-out limit from $5,000 to $7,000.
• Discretionary — Hardship self-certification: For plans that permit hardship withdrawals, decide whether the plan will rely on a participant’s self-certification regarding the need and amount.

Plan sponsors should not assume the recordkeeper, TPA or document provider has made every decision automatically. Ask for a written list of the amendments being adopted, confirm which optional provisions the plan has already implemented, and verify that the document, payroll, participant communications and day-to-day administration all match. My advice is simple: do not leave this for the last two weeks of December. Get the amendment package reviewed, approved and signed now, before year-end projects and holiday schedules turn a manageable task into an unnecessary fire drill. Is your retirement plan advisor discussing these items with you? Reach out to learn more.