Recently issued IRS Notice 2026-48 provides initial guidance on the Saver’s Match created by SECURE 2.0 largely to replace the current Saver’s Tax Credit. Under the Saver’s Match, beginning in 2027, eligible taxpayers with a maximum modified adjusted gross income (MAGI) of $35,000 ($71,000 for married filing jointly) are eligible to receive a matching contribution equal to 50% (reduced across a phaseout range as MAGI increases) of qualified retirement savings contributions up to $2,000. Qualified retirement savings contributions include contributions made by the taxpayer to a traditional or Roth IRA, elective deferrals to a 401(k), 403(b), or governmental 457(b) plan, SIMPLE 401(k) or IRA, SEP, and certain other specified contributions. Taxpayers will claim the Saver’s Match on a form filed with their tax return.
The Saver’s Match will be made by the Treasury Department directly to the plan or IRA, with the first match paid in 2028. The plan or IRA will treat the Saver’s Match as a pretax elective deferral contribution.
The Notice describes three paths the Treasury Department and the IRS are considering for making the Saver’s Match to a plan (this differs for an IRA): 1) the plan provides registration information, then the Treasury Department establishes a conduit IRA for the participant, and the conduit IRA rolls over the Saver’s Match to the plan; 2) an automatic match path similar to auto-portability; and 3) the Treasury Department establishes a conduit IRA for the participant, and the participant initiates the rollover to the plan.
Plans are not required to accept the Saver’s Match. As confirmed in the Notice:
- If a plan decides to accept the Saver’s Match, the plan needs to be amended by the end of the plan year in which it is added to the plan. But the plan can be amended prospectively to remove the Saver’s Match without violating the anti-cutback rules of section 411(d)(6) of the Internal Revenue Code and section 204(g) of ERISA. Note that the Saver’s Match is subject to reporting on Form 5500.
- If a plan chooses not to accept the Saver’s Match, no amendment is needed. In addition, no amendment is needed to accept rollovers of a participant’s account from an eligible retirement plan that includes the Saver’s Match. However, to make it clear for participants, we suggest stating in the plan’s summary plan description that the plan does not accept the Saver’s Match.
The Treasury Department and the IRS intend to issue regulations consistent with the Notice.
If you have questions about the Saver’s Match, please contact a member of the Faegre Drinker benefits and executive compensation team.
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