{"id":7069148,"date":"2026-09-28T14:00:29","date_gmt":"2026-09-28T14:00:29","guid":{"rendered":"https:\/\/peraltafinancing.com\/accounting\/extended-deadline-secure-act-2-0-provisions\/"},"modified":"2026-09-28T14:00:29","modified_gmt":"2026-09-28T14:00:29","slug":"extended-deadline-secure-act-2-0-provisions","status":"publish","type":"post","link":"https:\/\/fivemor.com\/?p=7069148","title":{"rendered":"Extended Deadline SECURE Act 2.0 Provisions"},"content":{"rendered":"


\n<\/p>\n

\n

September 24, 2026<\/p>\n

\"IRS<\/div>\n

The IRS has recently clarified that plan sponsors will have additional time to adopt<\/a> certain required plan amendments under the SECURE Act and SECURE 2.0 Act.<\/a> Although previous guidance established a general December 31, 2026, deadline for many SECURE-related amendments, some required changes. It is important to note; the clarification does not eliminate the 2026 deadline. Discretionary amendments for optional provisions a plan sponsor chose to implement generally remain due December 31, 2026. As year-end approaches, plan sponsors should understand which amendments require action now and which will have more time. To help clients, prospects, and others, Wilson Lewis has summarized the key details below.<\/p>\n

Background<\/h3>\n

The SECURE Act of 2019 and SECURE 2.0 Act of 2022 introduced numerous changes affecting retirement plans, including new rules for automatic enrollment, catch-up contributions, required minimum distributions and long-term, part-time employees. In Notice 2024-2<\/a>, the IRS extended the deadline for some amendments related to SECURE and SECURE 2.0 until December 31, 2026. Later deadlines apply to certain collectively bargained plans, governmental plans and 403(b) plans.<\/p>\n

There were still questions, however, about how that deadline interacted with the IRS Required Amendments List<\/a>. On September 16, 2026, the IRS clarified<\/a> that the appropriate deadline depends on whether an amendment is required or discretionary.<\/p>\n

What Changed<\/strong><\/p>\n

Required amendments generally follow the Required Amendments List (RA List) process. When a change appears on a list, the plan amendment deadline extends through the end of the second calendar year following the year the change is listed. The IRS also indicated that required changes that have not yet appeared on a RA List can be expected to appear on the future list.<\/p>\n

As a result, several SECURE and SECURE 2.0 requirements will have amendment deadlines later than December 31, 2026:<\/p>\n