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12.11.25

It’s been whirlwind of a year, and we’ve survived in pretty good shape.

Before popping the champagne bottles for the new year, though, let’s make sure your plans (and your clients) are set up to start the new year on the right foot.

The Year-End Crunch

The last couple of months of the year is an important window, for everything from notices to census cleanup happens now, a timeline on warp speed because of the holidays.

The September CPI was released according to schedule and projected 2026 limits are circulating as we speak. However, the government shutdown has slowed everything down, so it’s not known when the official limits will be released.

Experts tend to agree that a $1,000 increase will be made to the maximum 401(k), 403(b), and eligible 457 contributions for employees, which will raise the limit to $24,500 in 2026 from $23,500 in 2025. The regular catch-up limit will also increase from $7,500 to $8,000 in 2026. One of the key questions that remain is whether employees age 60-63 will receive an increase.

Distribute Annual Participant Notices

Year-end participant notices are a familiar checklist item, and it wouldn’t be year-end without the flurry of notices that need to go out between now and the end of December. The good news is that most of them share the same general window, so they can go out together, coordination that can save a lot of time.

Annual Participant Notices
Notice
  • Safe Harbor Notice
  • Automatic Enrollment / QACA Notice
  • QDIA (Qualified Default Investment Alternative) Notice
  • Safe Harbor Nonelective Notice (if applicable)
  • Participant Fee Disclosure (ERISA 404a-5)
Deadline / Timing
  • Must be provided at least 30 days and no more than 90 days before the beginning of the plan year. 📅 For the 2026 plan year: between Oct 3 and Dec 2, 2025.
  • Same 30-to-90-day window as the Safe Harbor notice. 📅 Oct 3 – Dec 2, 2025.
  • Must be provided at least 30 days before first investment in a QDIA and annually thereafter within the 30-90-day window before the new plan year. 📅 Oct 3 – Dec 2, 2025.
  • 📅 Dec 2, 2025, for 2026 plan year (if required).
  • Must be furnished at least annually (no more than 12 months after the last statement). Many TPAs align delivery with other year-end notices for efficiency.

Review Plan Documents and Amendments

Several mandatory changes are due in 2026 that demand attention now. We’ve been adapting to new provisions since SECURE 2.0 took effect in 2023, and 2026 won’t be any different—but this round includes two of the most significant updates yet. The best way to stay ahead is to start planning now—reviewing both procedures and plan documents to be sure everything lines up before the new year.

  • Mandatory Roth Catch-up Contributions. Beginning in 2026, catch-up contributions will look very different for high earners. Those with wages over $145,000 (indexed for inflation) from the plan sponsor must make their 401(k) catch-up contributions as Roth (after-tax) deferrals instead of pre-tax. This change applies only to catch-up contributions—not to regular elective deferrals or employer contributions. Heads-up: If your plan doesn’t currently allow Roth contributions it may be time to add that feature or high earners won’t be able to make any catchups at all. Plan sponsors should also confirm that this provision—and other SECURE 2.0 updates—are captured in their Cycle 4 document restatement, due no later than July 31, 2026.

  • Long-Term, Part-Time (LTPT) Employee Participation. Starting in 2026, part-timers who work at least 500 hours per year for two consecutive years in both 2024 and 2025 must be allowed to participate in your 401(k) plan—a change from the original three-year rule. Plan sponsors should make sure payroll can track hours accurately and that their service providers can do the same. And while you should already be tracking hours, plan documents don’t have to formally reflect the change until the 2026 amendment deadline.

  • Paper Statements Are Ba-ack! Beginning in 2026, 401(k) and other defined contribution plans must send at least one paper statement each year to every participant, unless the participant has opted into e-delivery or there isn’t a valid mailing address on file.

  • Optional or Discretionary Amendments. While you’re at it, take care of any discretionary design changes made during 2025—amendments for these are due by December 31, 2026.

  • Confirm RMDs and Terminated Participant Processing. As the year winds down, check Required Minimum Distributions (RMDs) one last time.  SECURE 2.0 changed the required beginning date to age 73 (for anyone born between 1951 and 1959) which has tripped up some systems. Make sure birthdates are accurate and coordinate with custodians to be sure all 2025 distributions are processed by December 31. A few minutes spent confirming RMDs and cleaning up terminations now can save hours making adjustments during audit season.

Reconcile Plan Assets and Participant Accounts

Before closing the books on 2025, take time to reconcile total plan-level trust totals with participant balances. Resolve any unallocated forfeitures or suspense accounts and confirm that all deposits have been made and employer contributions have been correctly allocated to participant accounts according to plan provisions. A clean reconciliation now saves hours of troubleshooting later during testing or 5500 preparation.

Clean up 2025 census data

True, final census files can’t be collected until early January but reviewing preliminary data now will pay dividends later. Flag missing hire or birthdates, Social Security numbers, or eligibility codes so they can be corrected before testing season. Also confirm that 2024–2025 part-time hours are accurate since 2026 will be the first full year LTPT employees are eligible under the 2-year lookback rule. Clean data shortens testing season — and the Stax.ai CX platform helps by automatically flagging inconsistencies before they can slow you down.

Wrap-Up

Each plan year brings its own challenges, but preparation always pays off. A few preventative steps now—scrubbing data, checking documents, and confirming year-end processes—will make next year smoother for everybody.

And before you know it, we’ll all be back here again at the end of 2025—to wash, rinse, and start the process all over again.

Closing Thoughts

Automation is king! Hail to the king! Accurate data and efficient processes are tools that keep every plan year running smoothly. The Stax.ai CX platform helps TPAs and plan sponsors get there by automating census data reviews, validating data early, and catching inconsistencies before they become time-eating problems.  It can also simplify your next testing season and save valuable time with Form 5500 preparation.

To see how Stax.ai can simplify your year-end and testing process, contact us to schedule a brief demo.

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