Defined Contribution Plan Key Priorities
Please note: These provisions may be prioritized differently based on your individual business needs.
| KEY PRIORITIES – APPLICABLE IN 2023 | Bill Provision Section |
| Increase in age for required beginning date | 107 |
| Reduction in excise tax for missed RMD | 302 |
| Modification of credit for small employer pension plan startup costs | 102 |
| Small employer pension plan startup credit for employers that join an existing plan | 111 |
| Availability of 403(b) MEPs/PEPs | 106 |
| Named fiduciaries for collecting contributions in PEPs | 105 |
| Annual audit clarification for group of plans | 345 |
| Eliminating unnecessary notices for unenrolled participants | 320 |
| Penalty exception for distributions to individuals with a terminal illness | 326 |
| Repayment of qualified birth or adoption distributions | 311 |
| Treatment of employer plan contributions as Roth contributions | 604 |
| Small immediate financial incentives for contributing to a plan | 113 |
| Retroactive first year elective deferrals for new plans for sole proprietors | 317 |
| Employer reliance on employee certification for deemed hardship distributions | 312 |
“Applicable in 2023” includes those provisions with effective dates stated as plan years beginning after date of enactment or after December 31, 2022; taxable years beginning after date of enactment or after December 31, 2022; or on or after the date of enactment; and any retroactive effective dates.
| KEY PRIORITIES – APPLICABLE IN 2024 | Bill Provision Section |
| Designated Roth account assets exempt from RMDs |
325 |
| Cashout dollar limit increase from $5,000 to $7,000 | 304 |
| Certain catch-up contributions must be treated as Roth contributions | 603 |
| Additional nonelective contributions to SIMPLE plans | 116 |
| Increase in deferral and catch-up contribution limit for SIMPLE plans | 117 |
| Surviving spouse may elect to be treated as deceased participant for RMD purposes | 327 |
| Enhancement of 403(b) hardship distribution rules | 602 |
| SIMPLE retirement accounts may be replaced with safe harbor 401(k) plans midyear | 332 |
| Retroactive amendments to increase benefit accruals | 316 |
| Starter 401(k) and safe harbor 403(b) plans for employers with no retirement plan | 121 |
| Student loan payments treated as elective deferrals for purposes of matching contributions | 110 |
| Emergency savings withdrawals from plans | 115 |
| Emergency savings in pension linked emergency savings accounts | 127 |
| Penalty free withdrawals for individuals in case of domestic abuse | 314 |
| Automatic portability transactions | 120 |
“Applicable in 2024” includes those provisions with effective dates stated as plan years beginning after December 31, 2023, or taxable years beginning after December 31, 2023.
| KEY PRIORITIES – APPLICABLE IN 2025 AND LATER | Bill Provision Section |
| Expanding automatic enrollment in retirement plans* | 101 |
| Saver’s match contributions | 103 |
| Improving coverage for part-time workers | 125 |
| Requirement to provide paper statements | 338 |
| Higher catch-up contribution limit to apply at ages 60 through 63 | 109 |
| Plan amendments for SECURE 2.0 | 501 |
| Distributions for purchase of long-term care contracts | 334 |
* Auto enrollment/increase feature isn’t required in plans until 2025 but all plans established on or after December 29, 2022, will need to add auto enrollment/increase features.
“Applicable in 2025 and later” includes those provisions with effective dates stated as “plan years beginning after December 31, 2024, or taxable years beginning after December 31, 2025.
For a more complete list of SECURE 2.0 provisions, please review the Congressional Summary, released by the Senate Finance Committee on December 19, 2022.
Click here for a printable version.
