Most plan sponsors have treated December 31, 2026, as the deadline for adopting plan amendments under the Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act) and the SECURE 2.0 Act of 2022 (SECURE 2.0). On September 18, 2026, the Internal Revenue Service (IRS) clarified in its Employee Plans newsletter that the deadline depends on whether an amendment is required or discretionary.
Certain required amendments follow the IRS Required Amendments List (RA List) process and will have deadlines after 2026. Discretionary amendments generally remain subject to the December 31, 2026, deadline.
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