It’s Not Just You: 2026 Feels More Complicated for Retirement Plans, because It IS More Complicated!
If administering a retirement plan feels more complicated than it used to, you’re not imagining it.
The changes taking effect in 2026 are a continuation of several years of phased-in legislation, inflation adjustments, and regulatory guidance, much of it stemming from the SECURE 2.0 Act of 2022. Add in changes that took effect in 2024 and 2025, and the result is a retirement plan environment with more moving parts than many employers and participants are equipped to manage.
Here’s what’s changing, and why 2026 stands out.
How 2026 Is Different
In past years, retirement plan updates had been relatively predictable: contribution limits increased modestly, income thresholds were adjusted based on inflation, and plan sponsors would make routine updates to their plans.
2026 is different because:
- Multiple, delayed SECURE 2.0 provisions finally take effect at one time
- Contribution strategies, not just amounts, are shifting
- Employers are managing overlapping compliance timelines
- Participants and employers are navigating new tax rules, particularly for catch-up contributions
In other words, it’s not simply more numbers; it’s also more decision-making. Throughout this article we break down the various ways 2026 is more complicated, and how to make it easier.
Delayed SECURE 2.0 Provisions Are Finally Arriving
One of the biggest reasons 2026 feels more complex is that it represents a turning point for SECURE 2.0. While the law passed in late 2022, many of its most impactful provisions were intentionally delayed to give employers, recordkeepers, and payroll providers time to prepare.
Now, that runway has ended.
In 2026, plan sponsors are no longer just planning for SECURE 2.0—they’re having to actively administer to it. That means moving from theoretical discussions to real operational changes and challenges, including with plan amendments, payroll coordination, and participant communication. For many employers, this is the first year that multiple SECURE 2.0 changes intersect at once, rather than being addressed one at a time.
Contribution Strategies Are Changing—Not Just the Limits
Every year has historically brought new retirement plan contribution limits; most employers are accustomed to that rhythm. What’s different in 2026 is that the strategy around contributions is becoming a key part of the discussion, along with the typical changes to contribution amounts.
New rules around catch-up contributions and evolving eligibility thresholds are forcing employers and participants to think differently about how compensation strategies and savings are structured. For higher earners in particular, maximizing retirement savings may now involve additional coordination with their payroll providers and tax advisors, rather than making a simple increase to their deferrals.
Beginning January 1, 2026, Mandatory Roth Catch-Up Contributions take effect. That means that participants age 50+ who earned more than $150,000 in the prior year (2025) must make catch-up contributions on a Roth (after-tax) basis versus via a traditional, pre-tax basis, which are no longer permitted for these higher-earning participants.
This is a fundamental change in the way many individuals have approached retirement savings later in their careers, which has several implications:
- Participants may see higher current-year taxes
- Long-term tax planning assumptions may need to be revisited
- Employers must ensure their payroll providers are operationally capable of handling Roth catch-ups. Some examples include tracking who falls into this category and having policies and procedures in place for these new rules.
For some savers, taking advantage of the mandatory Roth catch-ups will be straightforward and beneficial. For others, it may require rethinking cash flow and tax strategies. This shift can feel uncomfortable, especially for participants who have relied on the same savings approach for years. And for employers, it raises a new challenge: explaining why someone’s contribution experience may look different, even if their income hasn’t changed dramatically.
More Rules Mean More Decisions
Taken together, these changes explain why 2026 feels heavier than prior years. It’s not just that there are more rules—it’s that those rules require more judgment.
Employers are making decisions about possibly changing plan design, enhancing payroll processes, and expanding communication strategies. Participants are making decisions about how and where to save, often with new tax implications in mind. Advisors and administrators are helping bridge the gap between regulation and real-world impact.
The good news is that complexity doesn’t have to mean chaos. With the right planning, clear communication, and coordinated support, 2026 can be managed thoughtfully—and even used as an opportunity to improve plan outcomes. The addition of an experienced and conscientious TPA (Third Party Administrator) can help to bring order to the regulatory chaos.
For now, take a look at the Employer Checklist we put together to help Plan Sponsors see the changes ahead and make sense of them.
If you have questions about how these updates apply specifically to your plan, or would like a proactive review, our team is here and ready to support you.
