What Plan Sponsors Need to Know About the Secure 2.0 Amendment
Insights from Julie Thompson, Retirement Plan Consultant, Nydia Retirement Solutions
If you’ve received an amendment to your retirement plan document recently, you’re not alone, and there’s no cause for alarm. This is a routine but important step that every plan sponsor needs to complete before the end of 2026, and the team at Nydia is here to walk you through exactly what it means.
The Secure 2.0 Act was signed into law in December 2022, and while Third Party Administrators like Nydia have already been operating under the new rules, the IRS and Department of Labor now require that those rules be formally incorporated into your official plan document. Think of it as putting on paper what’s already been in practice.
Why the Amendment Is Happening Now
When major retirement legislation passes, there’s typically a period of clarification before official plan document language is finalized. The IRS and DOL issue guidance, tweak the rules, and work with plan document providers to get the language right. That process takes time, which is why you’re formalizing these changes now, even though the law has been in effect for a few years.
For most calendar-year plans, the amendment deadline is December 31, 2026. The good news: your plan has already been operating in compliance. Signing the amendment makes it official.
Key Secure 2.0 Provisions Worth Knowing
Secure 2.0 introduced over 90 changes to retirement plan rules. Not all of them will apply to every plan, but here are the provisions most likely to matter to Nydia’s clients:
Mandatory Auto-Enrollment (effective 2025)
New 401(k) and 403(b) plans established after December 29, 2022 are now required to automatically enroll eligible employees at a minimum contribution rate of 3%, with automatic annual increases of 1% up to at least 10%. Employees can opt out, but the default is now “in.” This provision is designed to increase participation, particularly among younger workers.
Super Catch-Up Contributions for Ages 60–63 (effective 2025)
Participants who turn 60, 61, 62, or 63 during the plan year are now eligible for an enhanced catch-up contribution, the greater of $10,000 or 150% of the standard catch-up limit. For 2025, that works out to $11,250, compared to the standard $7,500 for those 50 and older. This is an optional provision that plans can choose to adopt, and it’s a meaningful opportunity for late-career employees looking to accelerate their savings.
Mandatory Roth Catch-Up for High Earners (effective 2026)
This is the provision generating the most conversation heading into 2026. Starting this year, participants age 50 or older who earned more than $150,000 in FICA wages from your company in the prior year are required to make all catch-up contributions on a Roth (after-tax) basis, not pre-tax.
There are a few important implications for plan sponsors:
- Plans that offer catch-up contributions but do not currently have a Roth feature will need to either add Roth provisions or restrict catch-up contributions for affected high earners entirely.
- Payroll systems will need to identify eligible employees based on prior-year FICA wage data and route contributions correctly.
- The IRS has issued final regulations with a good-faith compliance transition period throughout 2026, with strict enforcement beginning in 2027.
Expanded Part-Time Employee Eligibility (effective 2025)
Secure 2.0 shortened the service requirement for long-term part-time employees to be eligible to contribute to your plan. Employees who have worked at least 500 hours in each of the past two years (down from three) are now eligible to participate. This is also now extended to 403(b) plans subject to ERISA.
RMD Age Increases
The age at which participants must begin taking Required Minimum Distributions has increased to 73 for individuals born between 1951 and 1959, and will increase further to age 75 for those born in 1960 or later, beginning in 2033. This gives participants more time for their savings to grow before mandatory withdrawals begin.
Not Everything Applies to Every Plan
One of the most important things Julie Thompson, Plan Consultant at Nydia, wants plan sponsors to understand: a long list of provisions doesn’t mean a long list of action items for you specifically. Many Secure 2.0 changes are optional, and many mandatory ones may simply not apply based on your plan’s design, size, or the demographics of your workforce.
The Nydia team is happy to go through the amendment with you line by line, reviewing what your plan has already been doing, identifying anything that may or may not apply, and walking through any optional provisions worth considering. It’s the kind of hands-on guidance that makes a complex document feel manageable.
What You Need to Do
The action item for plan sponsors is straightforward: review the amendment your plan provider has prepared and sign it before December 31, 2026. Your Nydia consultant will reach out to guide you through the process, answer any questions, and make sure everything is in order.
If you have questions in the meantime, about what’s changing, what it means for your employees, or whether there are optional provisions worth adopting, reach out. That’s exactly what we’re here for.
Have questions about your Secure 2.0 amendment? Connect with the Nydia team today.
