The SECURE 2.0 Act Amendment: What Employers Can Expect in 2026

The SECURE 2.0 Act of 2022 (SECURE 2.0) introduced the most sweeping set of retirement plan changes in more than a decade. While many provisions became operationally effective in 2023, 2024, and 2025, plans must formally adopt these changes through a written plan amendment. For most plans, that amendment must be adopted by December 31, 2026.

For plan sponsors, that raises a practical question: What should we expect from our 401(k) provider as that amendment deadline approaches?

This article walks through the amendment process employers should expect in 2026 to help clarify what decisions matter, which ones don’t, and when action is required.

For reference, you can review a sample SECURE 2.0 plan amendment with common default provisions here.

Why the SECURE 2.0 Amendment Matters

The SECURE 2.0 amendment process can feel overwhelming given the sheer number of changes introduced by the law, but it does not have to be. Most of the more complex SECURE 2.0 provisions are optional, and the administrative challenges associated with others can often be mitigated through relatively simple discretionary plan changes. The process also presents an opportunity to step back and reassess your plan design.

For most employers, the process will be straightforward:

1. 1. Receive notice from your provider
   2. Decide whether to make changes
   3. Receive the amendment
   4. File it with your plan records

A thoughtful provider will guide you through this process clearly—highlighting the decisions that matter, explaining the trade-offs, and avoiding unnecessary complexity.

Step 1: Amendment Notification is Received in the First Half of 2026

Your provider should notify you about the SECURE 2.0 amendment process—probably by email—during the first half of 2026. This notice should be more than a reminder about the amendment deadline. It should clearly explain how your plan will be amended by default and what choices, if any, you can make.

A well-structured notification typically includes four key elements.

Default SECURE 2.0 Provisions

To streamline the amendment process, most providers will apply a set of default SECURE 2.0 provisions to your plan. Unless you request other options, these defaults will apply automatically as of the amendment’s effective date.

In most cases, providers take a conservative, compliance-focused approach—requiring employers to affirmatively elect optional features rather than adopting them by default. The sample amendment excludes the following optional SECURE 2.0 provisions:

• • No Roth matching or nonelective contributions
  • No student loan matching
  • No emergency distributions
  • No emergency savings accounts
  • No automatic portability
  • No expansion of long-term, part-time (LTPT) employee benefits beyond statutory minimums

The sample amendment also includes defaults intended to reduce plan expenses, administrative complexity and compliance risk, such as:

• • Allowing participants to self-certify that they meet the requirements for a hardship distribution.
  • Increasing the involuntary force-out threshold to $7,000.

• •  Excluding otherwise excludable employees from top heavy minimum contributions.

Optional SECURE 2.0 Provisions

The notice you receive from your provider should also outline optional features you could adopt instead of the defaults, including:

• • Roth matching or nonelective contributions
  • Matching qualified student loan payments
  • Emergency, domestic abuse, disaster, or terminal illness recontribution features
  • Expanded LTPT employee eligibility for contributions, loans, or matching
  • A lower involuntary force-out limit

Importantly, these are plan design decisions, not compliance requirements. None of these options are mandatory.

Discretionary Amendments to Consider

In addition to SECURE 2.0–specific elections, your provider may highlight discretionary plan changes worth considering in light of new rules.

Add Roth Contributions

Beginning in 2026, certain higher-income participants will be permitted to make catch-up contributions only on a Roth basis. Plans that do not offer Roth contributions will be unable to accept catch-up contributions for those participants.

If your plan does not currently offer Roth contributions, you should consider adding the feature for the following reasons:

• • Preserves catch-up contribution flexibility for higher-income participants
  • Avoids future plan limitations for older, higher-paid employees
  • Requires no change to employer contribution formulas

Remove Hours-Based Eligibility Requirements

If your plan’s eligibility provisions include an hours-based service requirement (such as 1,000 hours), that requirement could produce a long-term, part-time (LTPT) employee—now or in the future.

Removing the hours requirement may be worth considering because it:

• • Eliminates the need to track LTPT eligibility
  • Simplifies plan administration
  • Reduces compliance risk tied to employee classification

Remove the Cash-Out Option for Force-Outs Under $1,000  

SECURE 2.0 permits plans to increase the involuntary force-out threshold to $7,000. However, some plans still allow vested account balances under $1,000 to be paid directly to participants by check, rather than being automatically rolled over to an IRA established on the participant’s behalf.

With the higher force-out limit now available, removing the cash-out option for balances under $1,000—and requiring all involuntary force-outs to be handled through IRA rollovers instead—may be worth considering because it:

• • Reduces the risk of uncashed or lost distribution checks
  • Helps ensure participant assets remain invested in a tax-advantaged retirement account

Key Dates and Next Steps

Finally, your provider’s notice should specify:

• • The deadline to request changes to the SECURE 2.0 amendment defaults
  • How to communicate requested changes
  • When you can expect to receive the formal amendment

Step 2: Request Changes to the SECURE 2.0 Defaults (If Any)

Once you receive the notice, what happens next depends on whether the default provisions are acceptable or you want to request changes.

• • Defaults are acceptable: Your provider may require no response at all or a simple confirmation. The notice should clearly state what, if anything, is required.
  • Changes are necessary: You must request any optional features or discretionary plan changes by the deadline specified in the notice so the amendment can be properly drafted.

Step 3: The Amendment Is Delivered in the Second Half of 2026

Most providers will deliver SECURE 2.0 amendments sometime in the second half of 2026—well ahead of the December 31 deadline.

What happens next depends on whether changes were made.

If You Accepted the Defaults

If no optional or discretionary changes were elected:

• • Confirm whether an employer signature is required
    • If no signature is required, no further action is needed and the amendment is final
    • If a signature is required, execute the amendment by signing and dating it

If You Requested Changes

If you elected any optional provisions:

• • Confirm the amendment reflects those elections accurately
  • Execute the amendment by signing and dating it
  • File the final amendment with your other plan records
  • Expect your provider to coordinate any related operational changes, participant notices, or payroll updates

Step 4: File the Amendment with other Plan Records 

ERISA requires employers to retain plan documents and records necessary to determine participant and beneficiary benefits. Under ERISA Section 209, these records must be retained for as long as they may be relevant—which, in practice, often means indefinitely.

Once your SECURE 2.0 amendment is final, it should be filed and retained with your other plan records.

SECURE 2.0 is an Opportunity with the Right Help! 

SECURE 2.0 introduced a wide range of changes, which can make the amendment process feel daunting at first. But most of the more complex provisions are optional, and many administrative challenges can be addressed through relatively simple plan design decisions.

A thoughtful provider will guide you through this process clearly—focusing on the decisions that matter and avoiding unnecessary complexity. If you have questions about how specific SECURE 2.0 provisions may benefit—or complicate—your plan, now is the right time to start that conversation.