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Your Year-End Compliance Checklist: Key Action Items to Raise with Plan Sponsor Clients

1. Plan Document Amendments: December 31, 2026 is the general deadline for most private-sector qualified plans and nongovernmental 403(b) plans to adopt certain written amendments reflecting the SECURE Act, CARES Act, and SECURE 2.0. Collectively bargained plans generally have until December 31, 2028, and governmental plans until December 31, 2029.

The IRS clarified on September 16, 2026 that discretionary (optional) SECURE and SECURE 2.0 amendments remain due by December 31, 2026. Required amendments instead follow the Required Amendments (RA) List cycle: the deadline is the end of the second calendar year after the item appears on an RA List. The Roth catch-up requirements under Section 603 are expected on the 2027 RA List, which would generally push that amendment deadline to December 31, 2029. Other items expected on future RA Lists include automatic enrollment, long-term part-time employees, and certain RMD provisions.

Advisors should confirm what the document provider’s package includes, that the document matches actual operations, and that the effective dates are correct. For calendar-year plans, any discretionary design change implemented during 2026 generally must also be adopted in writing by December 31, 2026.

2. Annual Participant Notices and Safe Harbor Decisions: Annual notices generally must be distributed 30 to 90 days before the plan year, making December 2 the key date for calendar-year plans. Safe harbor notices are generally required for match-based safe harbor plans and certain nonelective designs; QDIA notices apply to plans relying on QDIA relief; and automatic contribution arrangement (ACA, EACA, and QACA) notices apply to those designs. The packet may combine these notices, but the recipient list, delivery method, and actual distribution date should be confirmed separately.

December is also decision month for safe harbor status. An existing calendar-year 401(k) plan that did not provide safe harbor matching contributions during 2026 may be amended to become a 3% nonelective safe harbor plan for the current year by December 1, or a 4% nonelective safe harbor plan retroactively by December 31, 2027. December 31 is the deadline to remove or change safe harbor status for 2027, subject to exceptions and applicable advance notice requirements.

3. ADP/ACP Testing: For calendar-year plans that failed 2025 ADP or ACP testing and have not yet corrected, December 31, 2026 is the regular deadline to process corrective distributions (subject to a 10% excise tax) or, for plans using current-year testing, to make qualified nonelective contributions (QNECs). For the 2026 plan year, corrective distributions generally must be made by March 15, 2027 to avoid the 10% excise tax (June 30, 2027 for plans with an eligible automatic contribution arrangement covering all eligible employees for the year). Encourage clients to provide clean, complete census data promptly. For 2026 testing, an employee generally is a highly compensated employee (HCE) if he or she earned more than $160,000 in 2025 or is or was a more-than-5% owner during 2025 or 2026. The key employee compensation threshold for officers is $235,000 for 2026.

4. Required Minimum Distributions: Ongoing RMDs are due by December 31. The RMD age is 73 for individuals born in 1951 through 1958 and 75 for individuals born in 1960 or later; proposed IRS regulations specify age 73 for individuals born in 1959. A first RMD is generally due by April 1 of the following year, although a non-5% owner who is still working for the plan sponsor may generally delay it until retirement if the plan permits. Designated Roth contributions are exempt from lifetime RMDs. Missed RMDs can carry an excise tax of up to 25%, reduced to 10% when corrected timely.

5. 2026 Contribution Limits and Mandatory Roth CatchUp: Confirm that payroll is coded to stop deferrals at the right limits, and check Section 415(c) totals for owners and other high earners who may be receiving large employer contributions. The 2026 limits, announced by the IRS in Notice 2025-67, are:

Mandatory Roth catch-up contributions generally began January 1, 2026. A participant who is age 50 or older by year-end whose 2025 FICA wages from the plan sponsor exceeded $150,000 must make catch-up contributions on a Roth basis. Final regulations issued in September 2025 generally apply beginning in 2027, making 2026 a good-faith compliance year; verify before year-end that affected high earners satisfy the Roth requirement, taking into account earlier Roth elective deferrals. Correction methods include an in-plan Roth rollover and W-2 correction, subject to the regulations’ procedural and timing requirements; the W-2 method must be completed before that year’s W-2 is filed or furnished. No correction is required if a participant’s erroneous pre-tax catchups total $250 or less, excluding earnings.

The 2026 FICA wage review (generally using Form W-2, Box 3) will determine 2027 Roth catch-up status. The ages 60-63 super catch-up remains optional, but if one employer in a controlled group offers it, all applicable plans in the group generally must.

6. Form 5500 and Year-End Recordkeeping: The 2026 Form 5500 for calendar-year plans is due August 2, 2027, extendable to October 15 by filing Form 5558. Large plans, generally those with 100 or more participants at the beginning of the plan year (counting only participants with account balances for defined contribution plans; first year defined contribution plans use the year-end count), need an independent audit. An 80-to-120 participant rule may permit continued small-plan treatment. December 15 is the extended Summary Annual Report deadline (if required) for calendar-year plan whose 2025 Form 5500 was extended to October 15. Also confirm compliance with the 2026 annual paper benefit statement requirement for ERISA-covered defined contribution plans, taking account exceptions for electronic delivery and the DOL’s temporary good faith enforcement policy.

Key Takeaways: Year-end compliance is about keeping the sponsor, payroll provider, recordkeeper, and TPA aligned. Advisors who use a fourth-quarter meeting to confirm amendments, notices, testing data, distributions, and records help clients address issues while there is still time to fix them.

Reminders:

• December 2. General deadline to distribute applicable safe harbor, QDIA, QACA, and automatic enrollment annual notices to participants for the 2027 calendar plan year.
• December 15. Extended Summary Annual Report deadline (if required) for calendar-year plans whose 2025 Form 5500 was extended to October 15.
• December 31. Required minimum distributions for 2026; adoption deadline for certain SECURE, CARES, SECURE 2.0, and other discretionary amendments for most private-sector calendar-year plans; deadline to adopt amendments removing or changing safe harbor status for the 2027 plan year, subject to exceptions and applicable advance notice requirements.