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ARTICLE · 16 JULY 2026

The Clock Is Ticking: Retirement Plan Amendment Deadline Is Quickly Approaching

Calfee, Halter & Griswold LLP
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Plan sponsors of qualified retirement plans face a critical December 31, 2026 deadline to adopt formal amendments reflecting major legislative changes from the CARES Act, SECURE Act, and SECURE 2.0 Act. With less than six months remaining, sponsors must identify applicable provisions, coordinate with vendors and legal counsel, and ensure proper board approval to maintain compliance.

United StatesEmployment and HR
Nicolette T.E. Cregan
Nicolette T.E. Cregan
Robert A. Miller
Robert A. Miller
Sheila M. Ninneman
Sheila M. Ninneman
Jason A. Rothman
Jason A. Rothman
Erin E. Shick
Erin E. Shick
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Time is running out. Plan sponsors of qualified retirement plans must adopt formal amendments by December 31, 2026, to bring their plans into compliance with certain legislative changes.

Background

In recent years, Congress enacted a series of reforms to qualified plan rules: the Coronavirus Aid, Relief, and Economic Security Act (CARES Act); the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act); and the SECURE 2.0 Act (enacted December 2022). These three major legislative acts provided for both optional and mandatory provisions, including, but not limited to:

  • CARES Act – Provided temporary coronavirus-related distribution relief, waived required minimum distributions (RMDs) for 2020, and expanded plan loan limits for qualifying individuals affected by COVID-19.

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