As plan sponsors move past the Form 5500 deadline, it’s time to turn attention toward upcoming compliance dates and new regulations impacting benefit plans, particularly those from the SECURE Act 2.0. This act, which introduced significant changes to retirement plan administration, includes provisions that will take effect in 2025, bringing requirements like mandatory auto-enrollment and enhanced catch-up contributions for employees aged 60–63. Staying informed and preparing now for these adjustments will help ensure a smooth transition and ongoing compliance. Here’s what’s on the horizon and how to prepare.
Calendar 2024 Compliance Deadlines
November 14, 2024
- Participant fee disclosures due to participants for the calendar quarter ended September 30, 2024
- Safe harbor plans; this is the last day to provide the required annual safe harbor plan notice for the upcoming 2025 plan year
- QDIA notices; this is the last day to provide notices on qualified default investment alternatives for the upcoming 2025 plan year
- Auto-enrollment plans; this is the last day to provide the required annual auto-enrollment notices for the upcoming 2025 plan year
December 15, 2024
- Due date for Summary Annual Report (SAR) for the 2023 plan year (calendar plans); assuming the 5500 was extended to October 15, 2024
Calendar 2025 Compliance Deadlines
March 15, 2025
- Deadline for processing corrective distributions for failed non-discrimination (ADP/ACP) tests (to avoid 10% excise tax); for plan without automatic enrollment
July 1, 2025
- Deadline for processing corrective distributions for failed ADP/ACP tests (to avoid 10% excise tax); for plans with automatic enrollment
But, what about SECURE Act 2.0?
As provisions of SECURE 2.0 continue to become effective, it’s important to be aware of those that are applicable for the (calendar) 2025 plan year. Working with your third-party administrator and internal committees now will continue to ensure compliance with these provisions:
- Mandatory auto-enrollment
- If your 401(k) plan was established after December 29, 2022, the plan is required to implement an automatic enrollment provision for plan years beginning after December 31, 2024 (i.e. calendar 2025).
- Further information regarding plan establishment criteria can be found in IRS Notice 2024-2.
- Further considerations include working with your payroll providers and third-party administrators to ensure you have procedures in place to handle and process any opt-out requests for those not wishing to enroll in the plan
- Further information regarding plan establishment criteria can be found in IRS Notice 2024-2.
- If your 401(k) plan was established after December 29, 2022, the plan is required to implement an automatic enrollment provision for plan years beginning after December 31, 2024 (i.e. calendar 2025).
- Catch-up contribution increases
- For those participants who will attain ages 50 and over before the end of the plan year, the catch-up contribution remains at $7,500 (unchanged from 2024)
- However, for those participants who will attain ages 60-63 before the end of 2025, the maximum catch-up limit is increased to the greater of $10,000 or 150% of the regular catch-up contribution of $7,500 (i.e. $11,250).
- For those participants who will attain ages 50 and over before the end of the plan year, the catch-up contribution remains at $7,500 (unchanged from 2024)
Staying up-to-date on benefit plan deadlines and understanding the latest SECURE Act 2.0 requirements are essential steps in maintaining compliance and optimizing your organization’s retirement offerings. With new mandates like automatic enrollment and adjusted catch-up contributions on the horizon, early preparation will ensure a smooth transition into 2025 and beyond. At Meaden & Moore, our team of experts is ready to guide you through these regulatory changes, streamline compliance, and align your benefit plans with your company’s goals. Contact us today to see how we can support your compliance efforts and enhance your benefit strategies.
