One of the most promising provisions of the SECURE 2.0 Act was designed to solve a quiet retirement crisis: workers who skip 401(k) contributions because every spare dollar goes toward student loans. The fix lets employers count qualified student loan payments as if they were employee retirement deferrals — and match them. Eighteen months in, the data shows the benefit is real, but very few employers have actually rolled it out.
How the Match Works
Under SECURE 2.0 Section 110, an employer can treat a worker's qualified student loan payment (QSLP) as an elective deferral for matching purposes. If your plan offers a 5% match and you pay 5% of your salary toward student loans, you receive the employer match into your 401(k) — even though you contributed nothing to the plan yourself. Your retirement balance grows while your loans are being paid down.
The IRS issued final guidance in Notice 2024-63 that simplified compliance, and the matching contribution can be folded into a safe-harbor plan design without triggering separate nondiscrimination testing.
Adoption Has Been Slow
Despite the favorable rules, the rollout has stalled. According to industry research compiled by ASPPA and reported in Pensions & Investments, only about 1.9% of 401(k) plans had implemented the student loan match by the end of 2024, with adoption climbing modestly to 2.6% in a January 2025 survey. A separate sponsor poll found 55% of employers said they were "not at all likely" to add the provision in 2025, while only 12% described themselves as "very likely."
The reasons are mostly operational rather than philosophical. Plan sponsors cite administrative complexity, the need to verify loan payments, and competing HR priorities. Only 9% of consultants advising large defined-contribution plans said the provision was a top-12-month priority for their clients.
Early Adopters Are Concentrated
Large employers have led the way. Kraft, Workday, News Corp., Comcast, and Abbott Laboratories — which actually pioneered the concept through a 2018 private letter ruling before SECURE 2.0 codified it — are among the publicly identified adopters. Pharmaceutical and tech firms competing for younger talent have been overrepresented in early implementations.
What Employees Can Do Right Now
Ask HR directly. Many workers do not know whether their plan offers the QSLP match. The provision is optional, so plan documents must be amended to allow it. A simple question to your benefits team is the fastest way to find out.
Make the business case if it's missing. Decision-makers respond to retention data. If you are considering leaving for an employer that offers the match, say so. Surveys cited by Charles Schwab show younger workers consistently rank student loan benefits among the most valued non-salary perks.
Don't wait — keep contributing what you can. Even a 1% to 2% personal 401(k) deferral captures some employer match in most plans and gets compounding started. The 2026 elective deferral limit is $24,500, so there is plenty of headroom to add more once loans are paid off.
Track your loan payments carefully. When your employer does adopt the match, you will typically need to certify your qualified payments annually. Saving statements now makes that paperwork painless later.
For workers carrying federal or private student debt, the QSLP match is one of the most generous retirement provisions Congress has passed in a decade. The opportunity is on the books — the next step is making sure your employer puts it on the menu.
Sources: American Society of Pension Professionals & Actuaries (ASPPA), Pensions & Investments, Charles Schwab, Internal Revenue Service Notice 2024-63