
Ashley Bell, CPA
Partner
As the calendar turns, both retirement plan sponsors and participants have an important opportunity to review their 401(k) or 403(b) plan activity, assess compliance, and position themselves for a stronger year ahead. For plan sponsors, this is a critical time to confirm operational compliance and prepare for upcoming regulatory requirements. For participants, it is the perfect moment to adjust savings strategies and ensure their investments support long-term goals.
This article outlines the essential steps plan sponsors and plan participants should take annually.
Year-End and Beginning-of-Year Checklist for Plan Sponsors
✔ Confirm Required Year-End Compliance Tasks
Plan sponsors should begin by confirming required year-end compliance tasks. Contribution Limits and Nondiscrimination Testing should be reviewed to verify that annual deferrals did not exceed IRS limits, prepare for ADP/ACP and Top-Heavy testing if applicable, and confirm employer match and true-up contributions. Sponsors should also ensure 415(c) Annual Additions were not exceeded by confirming total employee and employer contributions remained within annual limits for each participant. In addition, Required Minimum Distributions (RMDs) should be reviewed to confirm all RMD-eligible participants took the required amount, as missed RMDs can lead to penalties.
✔ Evaluate Plan Operations and Administrative Procedures
Next, plan sponsors should evaluate plan operations and administrative procedures to ensure the plan has been administered correctly throughout the year. Payroll and Deferral Controls should be reviewed to confirm elective deferrals were withheld and deposited timely and that compensation definitions were applied correctly for contributions and testing. Sponsors should also examine Loan and Hardship Processes, including reviewing outstanding participant loans for accuracy and ensuring hardship withdrawals followed updated IRS substantiation guidance. Additionally, Plan Document and Amendments should be reviewed to confirm the document is up to date with required amendments, including SECURE Act, CARES Act provisions, and SECURE 2.0, and that any optional provisions adopted during the year were properly implemented.
✔ Benchmark Plan Fees and Service Providers
Plan sponsors should also benchmark plan fees and review service providers as part of their fiduciary oversight. Service Agreements should be evaluated to determine whether fees remain reasonable under ERISA guidelines and whether fiduciary responsibilities are clearly addressed. In addition, Investment Review meetings should be conducted to compare fund performance to benchmarks, evaluate share classes and expenses, and confirm that the qualified default investment alternative (QDIA) remains appropriate.
✔ Review Plan Participation and Education Strategies
Reviewing plan participation and education strategies is another important year-end task. Sponsors should assess Participation Rates to determine whether participation levels and savings rates align with organizational goals. They should also evaluate Communication and Education efforts by reviewing which education campaigns were effective during the prior year and developing a strategy for the coming year. This may include auto-enrollment adjustments, financial wellness webinars, or targeted campaigns for younger or lower-income employees.
✔ Prepare for Upcoming Year Requirements
Finally, plan sponsors should prepare for upcoming year requirements. Contribution Limits should be updated and communicated to employees. Sponsors should also review SECURE 2.0 Effective Dates, as key provisions—such as long-term part-time eligibility, Roth employer contributions, or catch-up Roth requirements—may require operational or system changes. In addition, establishing a Calendar of Fiduciary Deadlines can help ensure filing deadlines, testing dates, committee meetings, and notice distribution requirements are met throughout the year.
Year-End and Beginning-of-Year Checklist for Plan Participants
✔ Review Your Contribution Rate
Plan participants should begin by reviewing their contribution rate to determine whether their current savings level aligns with retirement goals. Contribution Levels should be evaluated by considering whether the employer match is being fully utilized, whether deferrals can be increased by 1–2%, and whether the annual contribution limit is approaching.
✔ Evaluate Investment Elections
Participants should also evaluate their investment elections to determine whether their investment mix remains appropriate. Investment Alignment should be reviewed by considering whether the target retirement age or goals have changed, whether the current allocation aligns with risk tolerance, and whether the portfolio has drifted due to market performance. Participants enrolled in target-date funds should still confirm the selected target year is correct.
✔ Consider Roth vs. Pre-Tax Contributions
Participants should consider Roth versus Pre-Tax Contributions to determine whether shifting some or all contributions to Roth may benefit their long-term tax strategy. This may be especially relevant for younger earners, those expecting income growth, or participants planning for tax diversification.
✔ Review Beneficiary Designations
Reviewing Beneficiary Designations is another critical step, as outdated beneficiaries are a common and costly oversight. Life events such as marriage, divorce, or the birth of a child should trigger an update.
✔ Verify Personal Information and Online Access
Participants should also verify Personal Information and Account Security by confirming email and mailing addresses are current, login credentials are active and secure, and account security settings such as multi-factor authentication are enabled.
✔ Check Loan and Withdrawal Activity
Participants should review Loan and Withdrawal Activity, including outstanding loan balances and repayment terms, and should avoid taking hardship withdrawals unless absolutely necessary due to their long-term financial impact.
✔ Evaluate Overall Financial Wellness
Finally, participants may benefit from evaluating Overall Financial Wellness by scheduling a financial consultation or using educational tools offered through their employer or recordkeeper. A holistic review may include emergency savings levels, debt management, and insurance and estate planning considerations.
Year-end and the beginning of a new year provide a valuable window for both plan sponsors and participants to assess retirement plan health and implement improvements. Sponsors strengthen fiduciary oversight and compliance, while participants ensure their savings strategies align with life goals.
Have questions or want help reviewing your plan?
Our Employee Benefit Plan team is here to help. Whether you are a plan sponsor navigating compliance requirements or a participant evaluating your retirement strategy, we encourage you to reach out to a member of our Employee Benefit Plan team today to discuss your specific needs.