Helping clients navigate SECURE 2.0 in 2026: Practical steps for TPAs

SECURE 2.0 has been a game-changer for retirement plans, and the last provisions are now coming into play for 2026. These provisions continue the legislation’s core objective of helping make it easier for employees to save and better understand their path to retirement. With additional IRS guidance providing more clarity, employers are ready to help their teams but might be looking for some direction. That’s where TPAs can step in and help make the process feel more manageable. As a proactive step, you can help guide clients through analysis and implementation and assist with corrections if needed. You’ll also be uniquely positioned to help turn plan requirements into advantages for clients and their employees.

Here’s a review of the most recent provisions that many clients are actively looking to address:

• Eligibility for long-term part-time employees (LTPT): As of 2025, employees who work at least 500 hours in two consecutive years (previously three years) are eligible to participate (permitted to make deferrals) in the retirement plan.
• Automatic (auto) enrollment and auto-increase are required for new plans: Beginning in 2025, 401(k) and 403(b) plans implemented after December 28, 2022, must auto-enroll eligible employees at 3%–10% deferral and auto-increase by 1% annually to at least 10% (max 15%) and include permissible withdrawals.
• Catch-up contributions as Roth: Beginning in 2026, employees earning $150,000+ (indexed) must make catch-up contributions on a Roth basis.
• Paper statements: Beginning in 2026, plans must provide participants at least one paper benefit statement per year unless the participant meets the requirements for electronic delivery. The Department of Labor recently issued proposed regulations that could change how plans can rely on e-delivery safe harbors for this new requirement. The proposed regulation is not final and could change following the close of the public comment period.
• Plan amendments: While many provisions were allowed to operate on good-faith compliance, most plans will need to be amended by December 31, 2026.

Even if these provisions aren’t mandatory, they can be game-changers for employees—and a differentiator for employers. By proactively discussing these options, TPAs position themselves as strategic partners who understand both compliance and workforce trends.

• Super catch-up contributions allowed for ages 60–63: Beginning in 2025, the catch-up contribution limit for 401(k) and 403(b) plans increased to the greater of $10,000 or 150% of the standard age-50 catch-up amount (for SIMPLE plans, it’s the greater of $5,000 or 150%).
• Roth employer contributions: Employers may allow participants to elect Roth treatment for future employer matching and nonelective contributions. This option can appeal to employees who want more control over how their retirement savings are taxed and who are looking to balance pre-tax and after-tax strategies.
• Student loan matching contributions: Employers can match student loan payments as if they were retirement plan deferrals. This is especially appealing for younger employees burdened by student loan debt. U.S. student loan debt totaled nearly $1.8 trillion as of early 2025 and is held by over 42 million Americans.
• Long-term care distributions: SECURE 2.0 allows penalty-free distributions of up to $2,500 per year for certain long-term care insurance premiums. While optional, this provision can support broader financial wellness strategies and resonate with those looking to balance retirement savings and long-term care planning.
• Qualified birth or adoption distributions: SECURE 2.0 allows plans to offer penalty-free withdrawals of up to $5,000 for a qualified birth or adoption, and participants have the option, but not the obligation, to repay the amount as a rollover contribution. This can give employees added financial flexibility during a major life event.
• Saver’s match: Beginning in 2027, the Saver’s Credit will be replaced with a Saver’s Match, which will provide a government matching contribution of 50% up to $2,000 in retirement savings for eligible lower-income participants. Although not immediate, early education might help employers prepare for the change.

SECURE 2.0 isn’t just a compliance exercise; it can often be confusing, time-consuming, and high-stakes for sponsors. Many are navigating these changes for the first time while juggling competing priorities. TPAs who lead with clarity and empathy have an opportunity to move from being administrators to trusted experts. Showing up as a steady, knowledgeable expert can help clients feel supported while helping deliver outcomes that align with their business goals. Here are ways to help position your firm as a leader:

Lead with insights. Offer scenario planning conversations that show how SECURE 2.0 provisions may affect workforce strategy, benefits competitiveness, and employee participation.

Provide resources that scale. Go beyond checklists. Develop templates, timelines, and communication strategies to help make implementation easier to manage.

Connect the dots: Show how compliance with the new provisions can support broader objectives such as employee retention, financial wellness, and operational efficiency.

Early action is key. Here are ways TPAs can set the stage to help clients move forward with both required and optional provisions:

1. Assess readiness: Review plan documents for compliance gaps and identify any payroll or recordkeeping changes needed. For example, confirm whether part-time eligibility rules are reflected in the plan language. If catch-up contributions are allowed, verify that Roth contributions are available within the plan.
2. Educate clients: Offer simple, digestible resources such as guides or webinars for HR and payroll teams. Clear communication can help build client confidence and help reduce errors.
3. Coordinate with vendors: Ensure payroll systems can handle Roth catch-up contributions and eligibility tracking for part-time employees.
4. Create a timeline: Map out milestones for what happened in 2025 and what’s coming in 2026. A visual roadmap can help clients prioritize tasks and allocate resources effectively.

As part of implementation, TPAs can help clients:

• Update plan documents early: Plan amendments can often take several months to draft, review and finalize, especially if multiple provisions are involved. Starting early may help avoid last-minute pressure and the risk that the plan will be run differently than the documents allow.
• Test payroll systems: Validate Roth catch-up functionality and eligibility tracking before going live. A quick test run now can prevent costly corrections later.
• Communicate with employees: Draft sample notices for clients to share with their workforce. Clear communication can build trust and help minimize errors.

Even with the best planning, errors can occur. Common issues include missed eligibility for part-time employees or incorrect tax treatment of catch-up contributions. Here’s how to address mistakes and help reduce the chance others may happen:

• Corrective actions: Use IRS correction programs (EPCRS) and document every step.
• Communicate with affected participants: Transparency matters—employees appreciate honesty and clear next steps.
• Proactive monitoring: Suggest periodic audits to catch issues early.