Estimated reading time: 4 minutes
Two SECURE 2.0 tasks get confused constantly, and the confusion is structural rather than careless.
The first is operational. Starting January 1 of this year, participants earning above a prior-year wage threshold were required to make any catch-up contributions as designated Roth contributions. Payroll and your recordkeeper handled the mechanics of that, or were supposed to.
The second is documentary. The plan itself has to be formally amended to reflect the change, and for most plans, that deadline is December 31, 2026.
The Roth catch-up piece gets the most attention because it’s the one with an operational deadline attached earlier in the year, but it isn’t the only provision this deadline covers. December 31, 2026 is when many plans need to formally adopt amendments for a broader set of SECURE 2.0 provisions, some of which may already be in place operationally without the plan document reflecting them yet. Worth confirming with whoever drafts your amendment exactly what it needs to cover.
Key Takeaways
- The SECURE 2.0 plan amendment deadline for most plans is December 31, 2026, and it’s separate from the Roth catch-up work payroll handled in January.
- The two tasks often sit with different people, which is how a plan can operate correctly all year against a document that was never updated.
- The eight months of operation since January are worth reviewing now, not just the amendment itself. Corrections found in-house are considerably less costly than the same issue found in an audit.
Why the Two Tasks Get Separated
They sit with different people. Payroll and the recordkeeper handle the operational side, because that’s where contributions are actually coded and processed. The plan document is usually maintained by a third-party administrator, sometimes by the recordkeeper, and occasionally by no one in particular if the relationships were never made explicit.
Which means it’s entirely possible for a plan to have operated correctly since January while the underlying plan document was never touched. Nobody did anything wrong. Nobody was assigned the second task, because everyone assumed someone else had it.
Whoever drafts your amendment, whether that’s your TPA, your recordkeeper, or outside counsel, the responsibility for ensuring it’s adopted on time rests with you as the plan sponsor. Delegating the drafting isn’t the same as delegating the obligation.
Two Things Worth Doing Before Thanksgiving
First, confirm who holds your plan document and whether the amendment has been drafted. This is a single email. If the answer comes back promptly and specifically, you’re in good shape. If it takes more than a day or comes back vague, that’s worth following up on directly.
Second, review the eight months of operation since January. Confirm that participants whose prior-year FICA wages exceeded $150,000, the 2026 indexed threshold, have been coded correctly for Roth catch-up treatment. Confirm that payroll files reconcile to what your recordkeeper received. Confirm that the required participant communication about the change actually went out, and to whom.
Why the Review Matters as Much as the Amendment
If any part of the operational side has been running incorrectly since January, that’s a correction issue, and corrections identified now, on your own schedule, are considerably less complicated than the same issue surfacing during an audit or a participant complaint.
The amendment deadline gets the attention because it has a date attached to it. The eight months of quiet operation underneath it’s where an error is more likely to actually exist.
If Nobody Has Raised This with You Yet
That’s worth noticing on its own.
A plan advisor who’s actively monitoring your plan’s compliance calendar should have flagged this deadline well before now, independent of anything else going on in the relationship. If this is the first you’re hearing of it, it’s a reasonable moment to ask what else might not be getting flagged.
This article is educational and does not constitute legal, tax, or investment advice. Plan document and payroll requirements should be confirmed with your third-party administrator, recordkeeper and qualified counsel. Marshall+Sterling Wealth Advisors, Inc. is a registered investment adviser and does not provide tax or legal services.
Frequently Asked Questions About the SECURE 2.0 Plan
For most plans, documents generally must be amended to reflect SECURE 2.0 provisions, including the Roth catch-up requirement, by December 31, 2026.
No. The Roth catch-up requirement is an operational payroll and recordkeeping matter that took effect January 1, 2026. The plan amendment is a separate documentary requirement with its own December 31, 2026 deadline.
Typically the plan’s third-party administrator or, in some arrangements, the recordkeeper. Sponsors should confirm directly which party holds this responsibility for their plan.
