10/9/25 Prepare for End-of-Year Employee BenefitsPlan Requirements
October 9, 2025
Several end-of-year compliance action items exist for both retirement and health plans. It is critical for all plan sponsors to have a clear to-do checklist by December 31.
Roth Catch-up Provisions
While there was hope that the Roth catch-up provisions might be delayed, final regulations were released on September 15, 2025, which retain the requirement that plans align with Secure 2.0 by January 1, 2026. This means that employees with wages greater than $145,000 in 2025 will be required to make any catch-up contributions as Roth contributions in 2026. This provision will require both an amendment to the plan as well as implementation for payroll and plan recordkeeping and administration purposes.
457(b) Non-Governmental Plans Amended for Secure 2.0
While many traditional retirement plans such as a 401(k) or 403(b) may have until 2026 to make amendments for Secure 2.0, nongovernmental 457(b) plans must be amended in most cases by December 31, 2025.
Department of Labor Audits Begin on Cybersecurity Policies
The U.S. Department of Labor (“DOL”) has been warning plan sponsors for the last several years regarding the requirements to maintain a proper and compliant Cybersecurity Policy. This requirement is for ALL benefit plans and not just those holding dollars in accounts such as a 401(k) Plan. Among other provisions, the DOL requires a written documented policy, with an at least annual risk assessment and a third-party audit of controls.
Health Plan Rates and Coverage Evaluation
While much of the current news is focused on ACA premium subsidy credits, the baseline cost of premium coverage impacts all employer-based health plans. As many employers begin to receive renewal proposals, there may be consideration to provisions, premium cost-sharing to different classes of employees as well as the potential use of high-deductible plans. In addition, coverage of benefits such as GLP-1 and tobacco surcharges have updated compliance considerations.
Please contact Jeff Robertson at 503-276-2140 or jrobertson@barran.com, Iris Tilley at 503-276-2155 or itilley@barran.com, or your regular attorney at Barran Liebman if you have any questions.