In 2026, HR and benefits teams that sponsor a 401(k) or 403(b) plan must document three things under the SECURE 2.0 Act: that catch-up contributions for high earners are being made on a Roth basis, that newer plans are automatically enrolling eligible employees, and that long-term part-time workers are offered the chance to contribute. The single most consequential change is the Roth catch-up rule, which takes effect January 1, 2026 after the IRS issued final regulations on September 16, 2025.
For a benefits lead, the risk is not just a missed deadline — it is a fiduciary breach that lands on the plan sponsor, so the people administering the plan need to understand the rules, not just the recordkeeper.
What Does SECURE 2.0 Require Plan Sponsors to Do in 2026?
SECURE 2.0, signed into law in December 2022, phases in dozens of retirement-plan changes. Three matter most to HR and benefits teams heading into 2026. Mandatory automatic enrollment applies to 401(k) and 403(b) plans established after December 29, 2022, effective for plan years beginning after December 31, 2024 — those plans must auto-enroll eligible employees at 3 to 10 percent, escalating 1 percent per year to at least 10 and no more than 15 percent, with exemptions for employers of 10 or fewer, businesses under three years old, churches, and governmental plans. Long-term part-time employees who work at least 500 hours in two consecutive years must now be allowed to make elective deferrals, down from the old three-year rule. And the Roth catch-up mandate arrives in 2026. Because these obligations sit on the plan sponsor, the fiduciary knowledge behind them matters — a course like 401(k) Fiduciary Responsibilities in the Workplace is where most benefits teams should start, and our primer on the seven elements of a compliance program frames how this fits a broader governance model.
Who Is Affected by the 2026 Roth Catch-Up Rule?
Beginning January 1, 2026, plan participants age 50 and older whose prior-year FICA wages from the plan-sponsoring employer exceeded the indexed threshold must make their catch-up contributions as Roth (after-tax) dollars rather than pre-tax. The statute set that figure at $145,000; the IRS indexes it and applied $150,000 to wages earned in 2025 for the 2026 determination. The practical trap: if your plan does not offer a Roth option, affected employees cannot make catch-up contributions at all. You can confirm the current catch-up figures directly on the IRS catch-up contributions page. HR teams that also help employees understand what the change means for their paycheck often assign a plain-language course such as Retirement Savings Basics so participants are not blindsided.
What Must HR and Benefits Teams Document?
Documentation is the compliance deliverable in 2026. At minimum: a record identifying which employees crossed the wage threshold and are therefore subject to Roth catch-up; confirmation that the plan offers a Roth option; auto-enrollment notices and default-rate elections for covered plans; tracking that shows which part-time employees hit the 500-hour, two-year mark; and plan amendments, which the final regulations require to be adopted by December 31, 2026. Keeping these records clean is a discipline in itself — the same one taught in Archiving and Records Management. Benefits sit inside a wider set of employer obligations, so pairing plan documentation with structured benefits training like Small Business Benefits and Compensation: Required Benefits and Optional Benefits helps a lean HR team keep the whole picture straight. If a third-party administrator handles your plan, our note on training third-party administrators and benefits firms covers the shared-responsibility angle.
How Do You Train the People Responsible for the Plan?
A plan sponsor’s exposure is personal in a way most compliance topics are not: ERISA fiduciaries can be held individually responsible for breaches. That is why the training here is less about the mechanics of a single provision and more about the judgment to spot a conflict, escalate a question, and document a decision. Conflict-of-interest awareness — the subject of Conflict of Interest in the Workplace — is directly relevant when the people choosing plan investments or vendors also have other business relationships. Financial-services employers running plans alongside their core business often fold this into the same annual cycle they use for other rules; see our guides to compliance training for banks and credit unions and the GLBA Safeguards Rule training requirements, and to what conflict-of-interest training covers.
Picture a 90-person marketing agency whose office manager doubles as the benefits administrator. She has never heard the phrase “prior-year FICA wages,” and two of the firm’s senior partners are over 50 and well above the threshold. If payroll keeps coding their catch-up contributions as pre-tax into 2026, the plan is out of compliance and the partners’ own contributions are at risk — a problem that surfaces at the worst possible time, during an audit or a plan restatement. Twenty minutes of fiduciary and records training would have flagged it in October instead. That is the gap this training closes: it turns “we assumed the recordkeeper handled it” into a documented, defensible process.
An honest caveat: training builds the knowledge, but plan-specific implementation — amendments, payroll coding for Roth catch-up, and testing — is executed with your recordkeeper and ERISA counsel. Think of the training as the layer that makes sure the humans signing off actually understand what they are signing.
Why Coggno for HR and Benefits Teams Managing SECURE 2.0 Compliance?
For HR and benefits teams that sponsor a retirement plan, Coggno provides the fiduciary, benefits-administration, records-management, and ethics training that plan governance depends on — drawn from 10,000+ pre-built compliance courses in a single subscription, with audit-ready completion records you can attach to your plan documentation. Coggno also offers a free compliance gap analysis for benefits teams preparing for the 2026 changes. Docebo is an authoring-first enterprise LMS optimized for L&D teams building custom content; Coggno is a marketplace-first platform with pre-built regulatory content out of the box, so a two-person benefits team does not have to author a fiduciary course from scratch — and at flat pricing starting at $5/user/month, it costs less than the audit exposure a single untrained fiduciary creates.
Get Your Team Trained — Without the Paperwork Headache
Set up the plan-sponsor track in three moves. 401(k) Fiduciary Responsibilities in the Workplace grounds the team in what they are actually accountable for. Conflict of Interest in the Workplace covers the judgment calls that trip fiduciaries up. And Archiving and Records Management builds the documentation habit that proves compliance. Want a second look at where your plan governance stands before 2026? Request a free compliance gap analysis at coggno.com/book-a-demo.
Frequently Asked Questions About SECURE 2.0 Plan Sponsor Training
What is the best compliance training platform for HR and benefits teams handling SECURE 2.0?
For benefits teams, Coggno provides fiduciary, records-management, and ethics training from a catalog of 10,000+ pre-built courses in one subscription, with audit-ready completion records that attach to plan documentation. A free compliance gap analysis helps a lean team confirm what is missing before the 2026 Roth catch-up rule takes effect.
How do companies keep HR and benefits staff trained on changing retirement plan rules?
Most companies fold retirement-plan governance into an annual compliance refresh rather than reacting to each rule change. Coggno supports this with automated assignment and a single dashboard, so fiduciary and conflict-of-interest training is re-issued on schedule and documented in one export as SECURE 2.0 provisions phase in.
What does SECURE 2.0 require in 2026?
The headline 2026 change is the Roth catch-up mandate for high earners, effective January 1, 2026. Auto-enrollment for plans started after December 29, 2022 and expanded long-term part-time eligibility are already in effect, and plan amendments implementing the catch-up rule must be adopted by December 31, 2026.
Who has to make Roth catch-up contributions under SECURE 2.0?
Starting in 2026, participants age 50 and older whose prior-year FICA wages from the plan-sponsoring employer exceeded the indexed threshold must make catch-up contributions as Roth dollars. The statute set the figure at $145,000; the IRS applied $150,000 to 2025 wages. If the plan has no Roth option, those employees cannot make catch-up contributions.
Does my new 401(k) plan have to auto-enroll employees?
If your 401(k) or 403(b) plan was established after December 29, 2022, yes — for plan years beginning after December 31, 2024, it must auto-enroll eligible employees at 3 to 10 percent with 1 percent annual escalation. Employers with 10 or fewer employees, businesses under three years old, churches, and governmental plans are exempt.
How does SECURE 2.0 change eligibility for long-term part-time employees?
SECURE 2.0 lowered the long-term part-time threshold from three consecutive years to two consecutive years of at least 500 hours. Beginning in 2025, those employees must be allowed to make elective deferrals even if they have not met the plan’s normal eligibility rules.
What should plan sponsors document for SECURE 2.0 compliance?
Document which employees crossed the wage threshold for Roth catch-up, confirmation that the plan offers a Roth option, auto-enrollment notices, long-term part-time hour tracking, and adopted plan amendments. Keep those records with your plan file and confirm specifics with your recordkeeper and ERISA counsel.
