Retirement Consulting Insights
Retirement Plan Outlook: What You Should Know for 2025
JANUARY 7, 2025
Marking your calendar with important compliance deadlines is an excellent way to plan for critical regulatory requirements and to avoid potential penalties for missed deadlines. Below is a summary of upcoming deadlines and action items for employer-sponsored retirement plans.
Retirement Plan Restatement and Amendment Requirements
Preapproved Defined Benefit (DB) Plan Document Restatement Deadlines: Under IRS Notice 2023-6, as part of the six-year remedial amendment cycle, sponsors of DB plans in an IRS-preapproved format have until March 31, 2025, to adopt a newly approved plan document restatement.
Preapproved 403(b) Plan Document Restatement Deadlines: Under IRS Notice 2024-38, as part of the second remedial amendment cycle, retirement plan sponsors of preapproved 403(b) plan documents must adopt the new preapproved restated plan on or before December 31, 2026.
Amendment Deadlines: Most retirement plan documents, under IRS Notice 2024-2, will have to be amended by December 31, 2026 (2028 for collectively bargained plans and 2029 for governmental plans), for the following legislation:
- The Setting Every Community Up for Retirement Enhancement Act (SECURE Act)
- The Bipartisan American Miners Act (Miners Act)
- The Coronavirus Aid, Relief, and Economic Security Act (CARES Act)
- The SECURE 2.0 Act of 2022 (SECURE 2.0 Act)
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For employers that have implemented optional changes under the SECURE Act, Miners Act, CARES Act or SECURE 2.0 Act: While amendments for such legislation are not required in 2025, these employers should continue to maintain documentation of processes and procedures regarding their implementation. |
Required Amendments List for Individually Designed Plan Documents: In IRS Notice 2024-82 (the most recent required amendments list), the IRS did not identify any changes that would require an amendment to most individually designed qualified or 403(b) plans in 2025.
Tools and Resources for Employers
Employers face compliance deadlines in 2025 that arise in the normal course of plan administration. This year also brings new cost-of-living limitations that apply to retirement plans. Below is information about these deadlines and limitations.
2025 Retirement Plan Compliance Calendars — Access detailed guidance on the regular administrative compliance deadlines:
2025 Cost-of-Living Adjustments — The IRS annually publishes cost-of-living adjustments (COLA) applicable to retirement plans and other employer-related plans. Access the 2025 guidelines:
Retirement Plan Impact and Recommended Action
In keeping with the Department of Labor’s (DOL’s) Missing Participants Best Practices for Pension Plans, USI Consulting Group (USICG) recommends that retirement plan sponsors maintain updated information regarding participants, beneficiaries, and alternate payees and procedures concerning benefit distribution. Benefits of doing this include:
- Improved plan administration
- Less pension overpayments, beneficiary disputes over death benefits, and expensive ERISA benefit claim litigation
- Better contact with former employees, which prevents abandoned benefits
- Facilitates domestic relations order determinations
How to maintain updated information and adequate procedures:
- Reach out periodically to current and former employees to confirm or update their contact information
- Review beneficiary designations on file to identify any potential issues (e.g., minor beneficiaries, trusts, improper completion or consent failures)
- Give participants regular opportunities to update beneficiary designations (e.g., prompt them to confirm information upon login to online platforms)
- Understand and communicate plan provisions regarding divorce’s effect on the designation of a spousal beneficiary
- Conduct periodic missing participant/beneficiary searches (e.g., use commercial locator services, public databases and proprietary internet search tools to locate individuals)
- Conduct periodic death audits to limit ongoing pension overpayments or improper survivor benefits
- Maintain qualified domestic relations order (QDRO) procedures
- Develop a Model QDRO for the retirement plan
- Learn rules under the SECURE 2.0 Act regarding limitations on correcting pension plan overpayments
- Review benefit distribution election forms and special tax notices
How USICG Can Help
Your retirement plan may have additional compliance requirements not listed here. USICG assists employers with all retirement plan compliance matters, including the impact from SECURE 2.0, to help mitigate risk and financial impact.
To learn more, please contact your local USICG representative, visit our Contact Us page, or reach out to us at information@usicg.com.
Follow USICG on LinkedIn to stay up to date with retirement news!
This information is provided solely for educational purposes and is not to be construed as investment, legal or tax advice. Prior to acting on this information, we recommend that you seek independent advice specific to your situation from a qualified investment/legal/tax professional.
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