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The countdown clock is running. The stadium lights are on, and the clock is ticking toward extra time. Plan sponsors must amend many qualified retirement plans by December 31, 2026. Just like in a World Cup knockout match, waiting invites costly mistakes.
Which Rule Changes Are Shifting the Field of Play?
Since 2019, three major laws have implemented both optional and mandatory changes to retirement plans.
- SECURE Act
In 2019, the Setting Every Community Up for Retirement Enhancement (SECURE) Act raised the RMD age, required long-term part-time employee eligibility, and replaced “stretch IRAs” with a 10-year payout rule.
Learn more: The SECURE Act, at Last - CARES Act
In 2020, the Coronavirus Aid, Relief, and Economic Security (CARES) Act added several provisions to help employers and participants during the COVID-19 pandemic, including coronavirus-related distributions, expanded loan limits, and a waiver of required minimum distributions (RMDs).
Learn more: The CARES Act Effect on Retirement Plans - SECURE 2.0 Act
At the end of 2022, SECURE 2.0 made yet another round of mandatory and optional changes, including expanded automatic enrollment, Roth catch-up contributions, and another increase to the required minimum distribution (RMD) age.
Learn more: Our 10-part series on SECURE 2.0.
Which Parts of Your Playbook Need Updating?
Common amendment areas include:
- Coronavirus-related distributions and loan provisions
- Waiver or treatment of 2020 RMDs
- Increased RMD age (now up to 73, with future increases)
- Long-term part-time employee eligibility rules
- Automatic enrollment and escalation features
- Updated required distribution timing rules
- Cash-out thresholds for small balances
- Roth catch-up provisions
Avoid a Stoppage-Time Scramble
No one wants to have to score in stoppage time under pressure with the entire stadium watching. Starting early gives you:
- Time to confirm operational compliance
- Flexibility to correct errors
- Better coordination with recordkeepers
- Stronger governance and documentation
Delays often expose gaps between operations and written terms.
Your Compliance Game Plan
1. Take Inventory – your full roster
Identify all plans and prior amendments.
2. Review Operations – like reviewing match footage
Confirm how CARES, SECURE, and SECURE 2.0 changes were handled in practice. Consult employee communications and Summaries of Material Modifications published since 2019.
3. Compare to Plan Language – close the gaps between strategy and execution
Spot differences between what you did and what your document says.
4. Draft Amendments – ensure every player is in the right position
Align the plan with the required and optional provisions you implemented.
5. Execute Before the Deadline – before the referee blows the final whistle
Complete approvals and adoptions on or before December 31, 2026.
Final Whistle
The IRS amendment deadline is approaching faster than a shot on goal. Many plan sponsors are already “playing by the new rules” but have not yet updated their documents. IRS Notice 2024-02 provides that, in general, the deadline to amend a qualified plan (that is not a governmental plan within the meaning of section 414(d) of the Code or an applicable collectively bargained plan) is December 31, 2026. This is the final match deadline with no extensions.
The content of this article is intended to provide a general guide to the subject matter. Specialist advice should be sought about your specific circumstances.
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