SECURE 2.0 in 2026: The Provisions Now in Full Effect and What Advisors Must Know

SECURE 2.0 was signed in late 2022, but many of its most consequential provisions were delayed to give plan sponsors, custodians, and advisors time to adapt. That adaptation period is largely over.

As of 2026, the key provisions are live. The question for advisors isn't "what's coming?" — it's "which of my clients haven't adjusted their plan for what already changed?"

This is a practical review of the provisions in effect now, sorted by client impact and advisor action required.

Provisions in Effect: High Client Impact

1. RMD Age Now 73 — and Moving to 75

SECURE 2.0 raised the Required Minimum Distribution starting age from 72 to 73 for individuals born in 1951 or later. For those born in 1960 or later, the RMD age will eventually rise to 75.

Where clients get confused:

Clients who had already started RMDs are not affected. But clients who were born in 1951 and thought they needed to start RMDs at 72 were given an extra year. The two-year delay for those born in 1960+ is still ahead.

Advisor action: For clients born 1951–1959 who haven't reached 73 yet, confirm they understand their correct RMD start date. For clients born in 1960 or later, update financial plans to reflect the extended deferral opportunity.

2. No RMDs from Roth 401(k) During Lifetime

Effective 2024, Roth 401(k) accounts are no longer subject to RMDs during the owner's lifetime. Previously, Roth 401(k) owners had to take distributions or roll to a Roth IRA to avoid them.

This change makes Roth 401(k) contributions dramatically more attractive — the account can compound tax-free without forced distribution, just like a Roth IRA.

Advisor action:

• Clients who were previously rolling Roth 401(k) to Roth IRA annually to avoid RMDs no longer need to
• Revise Roth vs. traditional contribution guidance for all accumulation-phase clients
• Model the long-term RMD impact for clients with large pre-tax 401(k) balances who could benefit from Roth contributions going forward

3. Enhanced Catch-Up Contributions (Ages 60–63)

Starting in 2025, workers aged 60–63 can contribute a larger catch-up amount — $11,250 in 2025 and 2026 — versus the standard $7,500 for those 50+ outside that window.

This creates a four-year window with $35,250 total 401(k) contribution capacity — $3,750 more per year than those just outside the range.

Advisor action: Proactively contact every client currently aged 60–63. Review their contribution elections. The enhanced catch-up is available now and requires no special action beyond adjusting the contribution percentage — but clients need to know it exists.

For clients earning over $145,000 from the plan sponsor: their catch-up contributions must now go to Roth 401(k). Confirm their plan is set up correctly and they understand the implications.

Provisions in Effect: Moderate Client Impact

4. Auto-Enrollment for New Plans (2025 Mandate)

Any new 401(k) or 403(b) plan established after December 29, 2022 must automatically enroll eligible employees starting in the plan year beginning after December 31, 2024 — which means 2025 and forward.

Auto-enrollment must start at 3% of compensation and automatically escalate by 1% per year to at least 10%, maximum 15%.

Who this affects: Advisors who work with small business owners and employer-sponsored plans. Any business that started a new 401(k) after late 2022 has this obligation now.

Advisor action: Contact employer clients who established new 401(k) plans in 2023 or 2024. Confirm auto-enrollment is configured correctly. Failure to comply can create plan qualification issues.

5. Emergency Savings Accounts Linked to 401(k)

Plan sponsors can now offer "pension-linked emergency savings accounts" (PLESAs) alongside 401(k) plans. These allow non-highly compensated employees to contribute after-tax dollars (up to $2,500) to a designated emergency savings account within the 401(k) plan. Contributions are Roth-style; withdrawals are penalty-free.

Advisor action: For advisors to employer-sponsored plans, flag this as an optional feature to consider during the next plan review. The participation rates aren't yet established, but for employee benefit purposes it may reduce the likelihood of early 401(k) withdrawals by employees with no liquid emergency savings.

6. Expanded Penalty-Free Withdrawals

SECURE 2.0 created several new penalty exceptions to the 10% early withdrawal penalty:

Advisor action: Update your mental model of withdrawal planning to include these exceptions. For clients facing hardship withdrawals, review whether a specific exception applies before defaulting to standard hardship rules.

Still Ahead: Key 2027 Provisions

A few significant provisions don't take effect until 2027:

• Catch-up contribution Roth mandate for all workers (not just those over $145,000): Currently the mandatory Roth catch-up applies only to high earners; there may be further regulatory guidance
• Super catch-up for SIMPLE IRA participants ages 60–63: Similar enhanced catch-up window for SIMPLE IRA plans

Advisor action for 2027: Begin planning conversations now for clients who will be in the 60–63 window in 2027 and have SIMPLE IRAs.

The Proactive Outreach Opportunity

SECURE 2.0 is the biggest set of retirement law changes in a generation. Most clients don't know the specifics — they know vaguely that "the rules changed."

The advisors who use this as a proactive outreach opportunity — not waiting for clients to ask — are demonstrating exactly the kind of value that retains clients and generates referrals.

A focused SECURE 2.0 review call (or detailed written summary) for every client over 55 is one of the highest-ROI activities available to advisors right now. The changes are real, the planning implications are significant, and most clients will appreciate being told rather than finding out on their own.

The law did the work of creating the conversation. Use it.