Retirement Consulting Insights
Mark Your Calendar: Key 2026 Compliance Updates for Retirement Plans
JANUARY 6, 2026
Start the new year by marking your calendar with important upcoming compliance deadlines. Below is a summary of important 2026 deadlines and action items for employer-sponsored retirement plans.
Retirement Plan Amendment Requirements
Pre-approved 403(b) Plan Document Restatement Deadlines: Under Internal Revenue Service (IRS) Notice 2024-38, as part of the second remedial amendment cycle, employers using a pre-approved 403(b) plan document format must adopt the new pre-approved restated plan on or prior to December 31, 2026.
Amendment Deadlines: Most retirement plan documents, under IRS Notice 2024-2, will have to be amended by December 31, 2026 (or 2028 for collectively bargained plans, or 2029 for governmental plans), for the following legislation:
- The Setting Every Community Up for Retirement Enhancement Act (SECURE Act)
- The Bipartisan American Miners Act (Miners Act)
- The Coronavirus Aid, Relief, and Economic Security Act (CARES Act)
- The SECURE 2.0 Act of 2022 (SECURE 2.0 Act)
Required Amendments List for Individually Designed Plan Documents: In IRS Notice 2025-60 (the most recent required amendments list), the IRS identified changes that would require an amendment to most individually designed qualified or 403(b) plans. Interestingly, Notice 2025-60 delayed the amendment deadline for such individually designed plans until December 31, 2027, for the required minimum distribution changes under the SECURE Act and SECURE 2.0 Act.
Tools and Resources for Employers
Employers face compliance deadlines in 2026 that arise in the normal course of plan administration. 2026 also brings adjusted cost-of-living limitations that apply to retirement plans. Below is information about these deadlines and limitations.
2026 Retirement Plan Compliance Calendars: Employers can access detailed guidance on the regular administrative compliance deadlines in the following calendars for defined benefit pension plans and defined contribution plans.
2026 Cost-of-Living Adjustments Affecting Retirement Plans: The IRS annually publishes cost-of-living adjustments (COLAs) applicable to defined benefit pension plans and defined contribution plans. Access the 2026 COLAs below.
Recommended Action for Employers in 2026
USI Consulting Group (USICG) recommends that employers maintain fiduciary files for their retirement plans.
There are many benefits of maintaining a fiduciary file for your retirement plan:
- Plan governance documentation organized in one convenient location
- Preparedness for audits by the plan’s accountant, IRS or U.S. Department of Labor (DOL)
- Preparedness for due diligence in the context of mergers and acquisitions
- Identification of potential compliance issues to address outside of enforcement
- Improved fiduciary structures and compliance, and mitigated liability
- Avoidance of administrative errors or missed deadlines
Here is a list of items you might maintain in your fiduciary file for your retirement plan:
- Governing plan document (including any basic plan document, adoption agreement, amendment, trust agreement, IRS determination letter, or IRS opinion letter) — in chronological order, all executed and dated
- Summary plan description (SPD), including any summary of material modifications thereto
- Retirement committee charter (or a list of plan provisions regarding governance), including any written delegations from the board of directors or other managing body
- Investment policy statement
- Funding policy (if applicable)
- ERISA fidelity bond
- Any liability insurance policy covering ERISA fiduciaries
- Service agreements with plan service providers (e.g., platform provider, investment advisor or manager, actuary, third-party administrator, or auditor), including ERISA fee disclosures
- Form 5500, all attachments and any audit report, for the last six plan years
- Form 8955-SSA, Annual Registration Statement Identifying Separated Participants With Deferred Vested Benefits, for the last six years
- Regulatory participant notices (e.g., safe harbor notice, blackout notice, participant fee disclosure, QDIA notice, summary annual report, or notice of reduction of benefit accruals) for the last six plan years
- Investment advisor plan performance reports from the plan’s investment advisor (including any service provider fee benchmarking) for the last six years
- Plan compliance testing (if applicable)
- Retirement committee minutes, in writing, documenting and explaining important committee decisions (e.g., qualification of domestic relations orders or beneficiary determinations)
- Governmental filings, routine or corrective
- Governmental correspondence during the last six years
- Actuarial reports (funding and accounting)
- Credit balance election forms
- Pension Benefit Guaranty Corporation Premium Filings (if applicable)
How USICG Can Help
Your retirement plan may have additional compliance requirements that are not listed here. USICG assists employers with all retirement plan compliance matters, including the changes from SECURE 2.0, to help mitigate risk and financial impact.
To learn more, please contact your local USICG representative, visit our Contact Us page, or reach out to us at information@usicg.com.
Investment advice provided to the Plan by USI Advisors, Inc. Under certain arrangements, securities offered to the Plan through USI Securities, Inc. Member FINRA/SIPC. Both USI Advisors, Inc. and USI Securities, Inc. are affiliates of USI Consulting Group.
This information is provided solely for educational purposes and is not to be construed as investment, legal or tax advice. Prior to acting on this information, we recommend that you seek independent advice specific to your situation from a qualified investment/legal/tax professional.
SUBSCRIBE
Get USI insights delivered to your inbox monthly.


