Retirement Plan Sponsors Face Year-End Decisions as SECURE 2.0 Deadlines, Pension Funding, and Form 5500 Rules Converge

Judy Chock of SingerLewak outlines key considerations for plan sponsors before the close of 2026

HONOLULU, HI, UNITED STATES, October 22, 2026 /EINPresswire.com/ -- As organizations approach year-end, retirement plan sponsors should focus on several significant developments that extend beyond routine compliance requirements. According to Judy Chock of SingerLewak, 2026 presents important opportunities and responsibilities related to SECURE 2.0 implementation, management of overfunded pension plans, and enhanced scrutiny of Form 5500 reporting accuracy.

Many employers are preparing critical SECURE 2.0 amendment deadlines while also evaluating the operational impact of new Roth catch-up contribution requirements. At the same time, sponsors of well-funded defined benefit pension plans are assessing de-risking opportunities, and regulators continue to emphasize the importance of accurate and consistent Form 5500 filings.

"Year-end compliance should be viewed as more than a checklist exercise," said Judy Chock, pension and employee benefits specialist at SingerLewak. "Plan sponsors should use this period to confirm that plan documents, administrative operations, payroll systems, and reporting procedures are aligned and functioning as intended."

SECURE 2.0 Compliance Requires Operational Readiness

For many nongovernmental, non-collectively bargained qualified retirement plans, December 31, 2026, represents an important deadline for adopting certain SECURE 2.0-related amendments. While governmental and certain collectively bargained plans generally have later deadlines, sponsors should not focus solely on document execution.

A key area of attention is the mandatory Roth treatment of catch-up contributions for higher-income participants. Beginning in 2026, employees whose prior-year FICA wages from the sponsoring employer exceeded $150,000 generally must make catch-up contributions on a Roth basis.

The requirement highlights the need for coordination among payroll departments, recordkeepers, benefits administrators, and legal counsel to ensure operational compliance and accurate participant classifications.

"Successfully implementing SECURE 2.0 requires more than updating plan language," Chock noted. "Sponsors need confidence that their systems are correctly identifying affected employees and administering catch-up contributions in accordance with the new rules."

Overfunded Pension Plans Present Strategic Opportunities

A pension plan with a funded ratio exceeding 100% may appear comfortably positioned, but sponsors should look beyond the headline percentage when evaluating long-term objectives.

For example, a plan with $109 million in assets supporting $100 million in liabilities may show a surplus today, yet changes in interest rates, investment performance, participant demographics, and actuarial assumptions can significantly alter future funding levels.

Organizations with frozen or mature pension plans may wish to explore de-risking strategies, including:

Liability-driven investment approaches

Lump-sum payment programs

Group annuity purchases

Eventual plan termination strategies

The most appropriate path depends on an employer's broader business and retirement plan objectives.

Sponsors should also recognize that pension surpluses remain subject to complex tax and ERISA requirements. While certain transfers of excess pension assets may be permitted under applicable law, careful planning and compliance review are essential before pursuing any such strategy.

Form 5500 Filings Demand Greater Attention to Accuracy

Industry professionals continue to emphasize that Form 5500 is more than an annual filing requirement. The report consolidates information regarding plan participation, assets, investments, funding, and operations, making inconsistencies more visible to regulators.

Plan sponsors are encouraged to review participant counts, reconcile financial information with trust and accounting records, confirm consistency with actuarial reports, and investigate significant year-over-year changes before filing.

Even minor errors, such as carrying forward incorrect information from a prior to filing or failing to reconcile data among service providers, can create reporting issues and increase regulatory scrutiny.

"An effective reconciliation process helps identify discrepancies before they become larger compliance concerns," Chock explained. "Taking time to validate information across all reporting sources can reduce risk and improve overall plan governance."

Looking Ahead

The common thread connecting these year-end priorities is governance. Whether addressing SECURE 2.0 requirements, leveraging strong pension funding positions, or improving regulatory reporting, plan sponsors benefit from a proactive approach that combines compliance with long-term strategic planning.

As 2026 ends, organizations have an opportunity to evaluate not only whether they are meeting regulatory obligations, but also whether their retirement plans are operating efficiently and supporting broader business objectives.

About SingerLewak

SingerLewak is a leading accounting and advisory firm providing audit, tax, business consulting, employee benefit plan, and advisory services to organizations across a wide range of industries. The firm assists clients with complex accounting, regulatory, compliance, and strategic business matters.

Judy Chock
SingerLewak