On September 18, 2026, the IRS used its Employee Plans News to answer a question sponsors had been asking quietly for two years: when does the paperwork have to catch up to the practice? The answer carries a fuse of about three months — and it lands hardest on features participants are already using.
The Near Deadline Covers Optional Features
Notice 2024-2 extends the deadline for SECURE and SECURE 2.0 discretionary amendments to December 31, 2026. Collectively bargained plans get until December 31, 2028; governmental plans and public school 403(b) plans until December 31, 2029.
"Discretionary" means optional — a feature the employer chose to add. Practitioner analysis of the guidance names the list: student-loan-payment matching contributions, pension-linked emergency savings accounts, Roth employer matching and nonelective contributions, domestic abuse victim distributions, terminally ill participant distributions, and qualified long-term-care distributions.
The IRS's own illustration is pointed. A plan that began letting participants designate matching or nonelective contributions as Roth in the 2023 plan year must adopt the implementing amendment by December 31, 2026 — three years after the feature went live for real money.
The Inversion Worth Understanding
Here is the counterintuitive part. Required amendments get more time, not less. A SECURE or SECURE 2.0 provision lands on a Required Amendments List only after the related final regulation generally becomes applicable, and the deadline is then the end of the second plan year after listing, under Rev. Proc. 2022-40.
So the mandatory Roth catch-up rule in SECURE 2.0 section 603 — the provision already redirecting high earners' contributions into after-tax dollars — is expected on the 2027 RA List, putting its amendment deadline around December 31, 2029.
Meanwhile the most-used optional provision sits on the near deadline. By year-end 2025, 91% of Vanguard-administered plans had adopted the enhanced age 60–63 catch-up limit, making it by far the most widely adopted optional SECURE 2.0 feature. That is a lot of savers relying on a benefit whose document language may still be in a to-do pile.
"Late" Is Not Automatically a "Failure"
This is where the primary text matters more than the summaries. EPCRS defines a Plan Document Failure and then states plainly that the term "does not include a failure to adopt a discretionary plan amendment by the plan amendment deadline." Several secondary write-ups compress this into "you cannot self-correct a late discretionary amendment." That is not what the revenue procedure says.
The real exposure runs the other direction: a plan operating a feature its document does not authorize has an operational mismatch, and significant operational failures must be corrected inside a defined window. The one thing EPCRS flatly bars from self-correction is the initial failure to adopt a qualified plan at all.
Practical Takeaways
- Ask what your plan added, and when. Request the current plan document and latest summary plan description. If you use a feature that is not described there, the amendment is probably still pending.
- Thin adoption is not irrelevance. The Plan Sponsor Council of America's annual survey found roughly 1.9% of plans match student loan payments and about 1.3% offer a PLESA — triple the prior year, with roughly 14% considering one. Small percentages, but if you are inside one of those plans, the written terms govern your balance.
- Separate what binds you from what is written. Roth catch-up treatment applies to your contributions now, whatever the document deadline says.
- Treat Q4 as the checkpoint. This is when recordkeepers and third-party administrators circulate amendment packages. A question in October is routine; the same question in January is cleanup.
Sources: IRS Employee Plans News (September 18, 2026); IRS Notice 2024-2; Ogletree Deakins, "New IRS Guidance Addresses SECURE and SECURE 2.0 Amendment Deadlines"; Rev. Proc. 2021-30 (EPCRS), section 5.01(2)(a); Rev. Proc. 2022-40; 401(k) Specialist, "SECURE 2.0: 91% of Plans Adopt Higher Catch-Up Limits" (Vanguard data); Plan Sponsor Council of America Annual Survey of 401(k) Plans.