SECURE 2.0 and 401(k) Auto-Enrollment: The 2026 Employer Checklist
SECURE 2.0 layered dozens of new 401(k) rules across a five-year implementation calendar. Here's what's live in 2026, what's coming, and what HR teams should be doing now.
The SECURE 2.0 Act of 2022 added more than 90 provisions to the retirement-plan rulebook on a staggered implementation calendar running through 2027. Several of the most consequential provisions for 401(k) sponsors land in 2026.
The auto-enrollment mandate
The headline change for 2026 is that all new 401(k) and 403(b) plans established after 29 December 2022 must include automatic enrollment for plan years beginning after 31 December 2024 — meaning calendar-year plans are subject from January 2025 onwards, but the design choices made in 2025 affect 2026 contributions.
Auto-enrollment specifications:
- Initial automatic contribution rate of 3-10% of pay
- Automatic escalation by 1% per year until reaching 10-15%
- Investment in a qualified default investment alternative (QDIA), typically a target-date fund
- Employee right to opt out and right to elect a different rate
Plans established before 29 December 2022 (and certain small employers, churches, and governmental plans) are exempt.
The Roth catch-up requirement
SECURE 2.0 originally required that catch-up contributions for participants earning over $145,000 in the prior year be made on a Roth (after-tax) basis. IRS Notice 2023-62 delayed the implementation date to 1 January 2026. Plans must now either offer a Roth source for affected high earners or stop accepting catch-up contributions from them entirely.
The student-loan match
From 2024 onwards (but with significant adoption still happening in 2026), employers may treat an employee's qualified student loan payment as an elective deferral for purposes of the employer match. The intent is to let workers who are paying down student debt still receive their full employer match without contributing to the plan directly.
Part-time employee eligibility
SECURE 2.0 reduced the long-service requirement for part-time employees from three consecutive years of 500+ hours (under the original SECURE Act) to two years, effective for plan years beginning in 2025. Part-time employees who clear that threshold must be allowed to make elective deferrals, even if they would not otherwise be eligible under the plan's age and service rules.
The 2026 HR/payroll punch list
- Confirm the plan document has been amended for SECURE 2.0 changes (the IRS extended the deadline to 31 December 2026)
- For affected high earners, configure the payroll system to direct catch-up contributions to a Roth source
- Verify auto-enrollment percentages and escalation are coded correctly for new hires
- If the plan offers a student-loan match, ensure the certification mechanic is in place
- Run the part-time eligibility analysis for plan years 2024 and 2025 to identify newly eligible workers
The Employee Benefits Security Administration publishes the DOL-side guidance for fiduciaries on each provision. For the underlying benefit-plan concepts, see our 401(k) glossary entry and the broader total compensation entry.