5 Employee Benefit Plan Trends Plan Sponsors Should Watch in 2026

Summary: Published for National 401(k) Day, this blog covers the biggest employee benefit plan changes sponsors and fiduciaries should watch in 2026, from mandatory Roth catch-up contributions to new SECURE 2.0 amendment deadlines. Moore Colson partner Candace Jackson breaks down five key trends, including fiduciary risk, shifting participant expectations and the growing role of technology in plan administration. Learn what plan sponsors and fiduciaries need to know to stay compliant and prepared in the year ahead.

Friday, September 11, 2026, marks National 401(k) Day, the annual reminder for workers to check in on their retirement savings and for plan sponsors to confirm their plans are keeping pace. This year, that means paying close attention to mandatory Roth catch-up contributions, new SECURE 2.0 amendment deadlines and other changes reshaping the employee benefit plan (EBP) landscape in 2026.

Here are five of the biggest trends influencing employee benefit plans in 2026.

1. What Are the New Roth Catch-Up Contribution Rules for 2026?

One of the most significant changes under SECURE 2.0 is the implementation of mandatory Roth catch-up contributions for certain higher-income participants.

Beginning in 2026, employees aged 50 and older whose prior-year wages from the sponsoring employer exceed the IRS threshold (indexed annually for inflation) must make catch-up contributions on a Roth basis rather than a pretax basis, if the plan permits catch-up contributions. Plans that offer catch-up contributions must ensure their payroll, recordkeeping and administrative systems are prepared to identify affected participants and properly process these contributions. The IRS also issued final regulations in late 2025 to clarify implementation requirements.

What plan sponsors should do:

• Monitor payroll systems to ensure these calculations are being treated correctly. While payroll systems may promise they are equipped to handle these changes, we’ve already seen some hiccups this year.
• Update participant communications to explain how the change affects retirement savings and tax planning.
• Train HR and benefits teams to answer employee questions.

2. SECURE 2.0 Amendment Deadlines Are Approaching

Although many SECURE 2.0 provisions have already become operational, formal plan amendments are still required.

For most non-governmental qualified retirement plans, the amendment deadline is December 31, 2026, giving plan sponsors an opportunity to align plan documents with operational practices. Waiting until year-end can create unnecessary pressure, particularly for organizations that have adopted multiple optional SECURE 2.0 provisions.

Now is an ideal time to review:

• Required versus optional SECURE 2.0 provisions
• Operational compliance since implementation
• Plan document updates
• Administrative procedures that may need revision

Early planning can help avoid last-minute corrections and reduce compliance risk.

3. Fiduciary Risk Remains a Top Concern for Plan Sponsors

Fiduciary responsibilities remain one of the greatest areas of concern for retirement plan sponsors. Regulatory scrutiny and participant litigation continue to focus on whether fiduciaries are acting prudently and solely in participants’ best interests.

Current areas of focus include:

• Investment monitoring and documentation
• Fee reasonableness
• Cybersecurity oversight
• Vendor selection and monitoring
• Participant data protection

Just as important as making prudent decisions is documenting the process behind those decisions. Well-maintained committee minutes, regular investment reviews and clearly defined governance procedures continue to be among the strongest defenses against fiduciary challenges.

Organizations should also revisit their fiduciary training programs to ensure committee members understand their responsibilities under the Employee Retirement Income Security Act (ERISA) and evolving regulatory expectations.

4. Participant Behavior Is Reshaping Retirement Plan Design

Today’s workforce expects retirement plans to provide greater flexibility, personalization and financial wellness support.

Employees are increasingly:

• Choosing Roth contributions over traditional pretax deferrals
• Seeking retirement income planning rather than simply accumulating assets
• Looking for digital education and self-service tools
• Expecting financial wellness resources beyond retirement savings

At the same time, participant demographics continue to diversify, requiring communications that resonate with multiple generations, from early-career employees to those approaching retirement.

Plan sponsors that understand participant behavior can often improve engagement, increase participation rates and help employees make more informed financial decisions.

5. Technology Is Transforming Retirement Plan Administration

Technology continues to reshape nearly every aspect of retirement plan administration.

Artificial intelligence, automation and advanced data analytics are helping plan sponsors and service providers streamline administrative processes, improve participant communications and identify operational issues more quickly.

Emerging technologies are supporting:

• Automated compliance monitoring
• Personalized participant education
• Predictive analytics for participant engagement
• Improved reporting and data integration

However, greater reliance on technology also brings increased cybersecurity responsibilities. Plan fiduciaries should regularly evaluate service providers’ security controls, incident response procedures and data governance practices as part of their ongoing oversight.

Preparing Your Plan for What’s Ahead in 2026

The pace of change in employee benefit plans shows no signs of slowing. SECURE 2.0 implementation and evolving fiduciary expectations continue to shape how plans operate, while shifting participant preferences and advancing technology are changing what employees expect from their plans.

Organizations that proactively review their plan operations, governance practices and participant experience will be better positioned to navigate regulatory changes while helping employees achieve stronger retirement outcomes.

A strong team of advisors, including auditors, legal counsel, third-party administrators and investment professionals, can help keep your plan compliant, efficient and aligned with best practices in an increasingly complex environment.

Contact the Moore Colson Employee Benefit Plan Audit team to talk through how these trends could affect your plan, your participants and your 2026 compliance calendar.

FAQ

What is a Roth catch-up contribution?

A Roth catch-up contribution is an additional retirement plan contribution for participants aged 50 and older that’s made with after-tax dollars, so qualified withdrawals in retirement come out tax-free. That’s different from a standard catch-up contribution, which is typically pretax.

Can 401(k) catch-up contributions be Roth?

Yes. Starting in 2026, 401(k) participants aged 50 and older whose prior-year wages exceed the IRS threshold are required to make catch-up contributions on a Roth basis. Participants below that threshold can still choose pretax catch-up contributions if their plan allows it.

What is the SECURE 2.0 amendment deadline?

For most non-governmental qualified retirement plans, formal amendments reflecting SECURE 2.0 provisions are due by December 31, 2026. Plans that have already implemented provisions operationally still need updated plan documents to match.

What are a plan sponsor’s responsibilities under SECURE 2.0?

Plan sponsors are responsible for adopting required plan amendments, updating payroll and recordkeeping systems to reflect new provisions and communicating changes clearly to participants. Sponsors should also confirm which optional provisions they’ve adopted so plan documents and operations stay aligned.

What should be on a 401(k) fiduciary responsibility checklist?

A strong checklist includes regular investment monitoring, documented fee benchmarking, a defined vendor selection and review process, updated committee governance procedures and periodic fiduciary training.

What cybersecurity responsibilities do plan fiduciaries have?

Fiduciaries are expected to evaluate service providers’ cybersecurity practices, including how they secure participant data, respond to incidents and monitor for vulnerabilities. The Department of Labor has signaled that cybersecurity oversight is part of a fiduciary’s prudent process, not a separate IT issue.

About the Author

Candace Jackson, CPA, is a Partner and the Assurance Practice Area Leader at Moore Colson. She serves as the firm’s technical expert in public and large private company employee benefit plans, including 401(k), 403(b), pension, ESOP, and health and welfare plans.