Benefits Counselor - October 2026

RETIREMENT PLAN UPDATES

IRS Guidance Addresses SECURE and SECURE 2.0 Amendment Deadlines

The Internal Revenue Service (IRS) recently clarified the deadlines for adopting required and discretionary plan amendments under the SECURE Act and SECURE 2.0. The IRS explained that discretionary amendments implementing optional SECURE or SECURE 2.0 provisions generally must be adopted by Dec. 31, 2026, with later deadlines applying to certain collectively bargained and governmental plans.

In contrast, required amendments generally must be adopted by the end of the applicable remedial amendment period, which depends upon when a qualification change appears on the IRS’s annual Required Amendments List. The IRS further noted that statutory changes requiring additional guidance generally will not appear on the Required Amendments List until that guidance has been issued and becomes applicable. Once a qualification change is included on a Required Amendments List, the remedial amendment period