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ARTICLE · 22 OCTOBER 2025

2025 Retirement Plan Year-End Amendments And Operational Compliance

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With the leaves changing colors and the holidays around the corner, it's time for retirement plan sponsors to review their plan documents to comply with year-end amendment deadlines, confirm operational compliance with changes in law, and satisfy participant notice requirements.

United StatesEmployment and HR
David Ashner
David Ashner
Randy Bunnell
Randy Bunnell
Kelly Geloneck
Kelly Geloneck
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With the leaves changing colors and the holidays around the corner, it's time for retirement plan sponsors to review their plan documents to comply with year-end amendment deadlines, confirm operational compliance with changes in law, and satisfy participant notice requirements. This is the case even though for most plans (see below for an exception for non-governmental 457(b) plans), the deadline to adopt amendments for changes in law under the SECURE Act, CARES Act, and SECURE 2.0 is no earlier than December 31, 2026.

Year-End Plan Amendments

Retirement plan sponsors need to consider the following potential year-end plan amendments:

  • Amendments for 2025 Plan Changes. Retirement plans will need to be amended by the end of the 2025 plan year for any "discretionary" plan changes that took effect in 2025. These discretionary changes may include plan design changes, changes in plan administration impacting the provisions in the plan document, and changes to plan

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