SECURE 2.0: What Sponsors Should Have Done by Now

SECURE 2.0 has been rolling out in waves since it was signed in late 2022. Several provisions that were optional or delayed are now in effect, and a handful more are coming. This is a quick orientation rather than a deep dive. The goal is to flag what should already be on a sponsor’s checklist.

Already in effect

• Mandatory auto-enrollment for new 401(k) and 403(b) plans established after December 29, 2022, with limited exceptions.
• Long-term part-time eligibility has tightened. Employees with two consecutive years of 500+ hours are eligible for elective deferrals.
• Roth catch-up contributions for high earners (over the $145k indexed wage threshold). Sponsors should confirm that payroll and recordkeeping are set up to enforce this.

On deck

• Saver’s match replaces the saver’s credit beginning in plan year 2027. This changes how lower-income participants are incentivized.
• Optional emergency savings accounts linked to retirement plans.

What this means in practice

Most of the heavy lifting is on the recordkeeper and payroll provider, but the plan document and the participant communications are the sponsor’s responsibility. If the SPD has not been updated since 2023, that is a good place to start.