Why SECURE 2.0 Is an IT Challenge, Not Just a Compliance Challenge
The SECURE 2.0 Act contains 92+ provisions rolling out on staggered timelines through 2033. For Third-Party Administrators, each provision creates ripple effects across plan administration software, payroll integrations, recordkeeper file transfers, compliance testing routines, and participant communications. Your TPA IT infrastructure needs to support all of it—reliably, securely, and on schedule.
Most industry coverage focuses on the legal and compliance implications. This guide focuses on what matters to your IT team: which systems need updating, what new data flows are required, and where cybersecurity exposure increases as a result.
2025
In effect
- Mandatory auto-enrollment (new plans)
- Enhanced catch-up, ages 60–63
- Long-term part-time eligibility (2 years)
- Automatic portability network
2026
In effect now
- Mandatory Roth catch-up for high earners
- Roth employer matching elections
- Annual paper benefit statements
- Lost & Found database submissions
2027+
Coming
- Roth catch-up full-compliance regulations
- Saver’s Match (2027)
- Emergency savings account maturation
- Rolling IRS/DOL implementing guidance
2025 Provisions Already in Effect
Mandatory Automatic Enrollment
What it requires: New 401(k) and 403(b) plans established after December 29, 2022 must include automatic enrollment at 3-10% of compensation with annual 1% escalation up to at least 10% (capped at 15%).
TPA IT impact: Plan administration systems need auto-enrollment defaults configured per plan, escalation schedules tracked per participant, and opt-out processing workflows. Payroll integrations must handle automatic deferral percentage changes at each escalation date. Compliance testing must verify the auto-enrollment safe harbor is applied correctly.
Enhanced Catch-Up Contributions (Ages 60-63)
What it requires: Participants aged 60-63 can contribute the greater of $10,000 or 150% of the standard catch-up limit (indexed for inflation).
TPA IT impact: Systems need age-based contribution limit tracking with a new tier between standard and catch-up. Payroll integrations must apply the correct limit based on participant age as of December 31 of the plan year. Your TPA software needs to distinguish between standard catch-up (age 50+) and enhanced catch-up (ages 60-63 only) for compliance testing.
Expanded Long-Term Part-Time Employee Eligibility
What it requires: Employees working 500+ hours for two consecutive years (reduced from three under SECURE 1.0) must be eligible to participate in the plan.
TPA IT impact: Hour tracking systems need to capture and maintain multi-year hours data for all employees—not just full-time. Payroll integrations must report hours accurately. Plan administration software needs eligibility rules that check consecutive-year thresholds. This increases the data volume flowing between payroll systems and your TPA, expanding both storage requirements and cybersecurity exposure.
Automatic Portability
What it requires: Default IRA balances under $7,000 can be automatically rolled into a new employer's plan through the Retirement Clearinghouse portability network.
TPA IT impact: Recordkeeper file transfer protocols need to accommodate portability transactions. Your TPA systems need to process incoming automatic rollovers and verify participant identity for each transfer. Cybersecurity controls around incoming fund transfers are critical—social engineering attacks targeting portability transactions are an emerging threat vector.
2026 Provisions Now in Effect
Mandatory Roth Catch-Up for High Earners ($145,000+)
What it requires: Since January 1, 2026, employees who earned $145,000 or more (indexed) in prior-year FICA wages must make all catch-up contributions as Roth (after-tax). Originally effective in 2024, the requirement was delayed by IRS Notice 2023-62; Treasury and IRS issued final regulations in September 2025 (opens in new tab), with a reasonable good-faith compliance standard applying in 2026 and full regulatory compliance required for taxable years beginning after December 31, 2026.
TPA IT impact: This is the most complex SECURE 2.0 IT change for TPAs. Systems must track prior-year W-2 compensation to determine who exceeds the $145,000 threshold, automatically route catch-up contributions to the Roth sub-account for affected participants, coordinate with payroll providers for correct tax withholding on Roth contributions, maintain audit trails showing the income determination for each participant, and update compliance testing to distinguish mandatory Roth catch-ups from elective Roth deferrals. The payroll integration changes alone require coordination between your TPA IT systems, the employer's payroll provider, and the recordkeeper—three separate data flows that all must stay accurate and synchronized now that the requirement is live.
Employer Matching to Roth Accounts
What it requires: Plan sponsors can elect to have matching and nonelective contributions directed to participants' Roth accounts (taxable at contribution).
TPA IT impact: Recordkeeper integrations need new transaction types for Roth employer contributions. Plan document systems need to support the Roth match election. Payroll feeds need to handle the different tax treatment. Compliance testing must account for Roth matching in ADP/ACP testing.
The Cybersecurity Dimension of SECURE 2.0
Every SECURE 2.0 provision that creates new data flows, new integrations, or new transaction types also expands your TPA's attack surface. More data moving between more systems means more potential breach points. Consider that long-term part-time employee tracking increases the volume of PII your systems process and store, automatic portability transactions create new entry points that threat actors could exploit, Roth catch-up income verification requires compensation data flowing between payroll, TPA, and recordkeeper systems, and student loan matching connects to employee student loan servicer data—another external integration.
This is why DOL elevated cybersecurity to a National Enforcement Project (opens in new tab) in January 2026 (see our DOL Cybersecurity Compliance Guide for the full requirements). The regulatory expectation is clear: as TPA operations become more complex under SECURE 2.0, cybersecurity controls must scale accordingly. Your TPA IT provider needs to understand both the compliance requirements and the security implications of each provision.
Provisions Coming in 2027 and Beyond
TPAs should begin planning IT infrastructure for additional SECURE 2.0 provisions on the horizon. Mandatory annual paper benefit statements took effect for plan years beginning after December 31, 2025—DOL proposed implementing amendments to the e-delivery safe harbors in February 2026 and issued Field Assistance Bulletin 2026-02 (opens in new tab) establishing a temporary good-faith enforcement policy while the rule is finalized. Document generation, print/mail pipelines, and e-delivery election tracking all need to reflect this. The $500 small-balance auto-cashout threshold increase to $7,000 (already effective) continues to generate portability transaction volume. New emergency savings account provisions require separate sub-account tracking. Expanded self-correction under EPCRS (already effective) requires enhanced audit trail capabilities to document corrections.
The full implementation timeline extends through 2033, with IRS and DOL issuing implementing regulations on a rolling basis. TPA IT systems need to be flexible enough to accommodate updates as guidance is finalized.
Common Questions
What SECURE 2.0 provisions require TPA IT system updates?
Key SECURE 2.0 provisions requiring TPA IT updates include: mandatory automatic enrollment for new 401(k) and 403(b) plans (2025), enhanced catch-up contributions for ages 60-63 (2025), mandatory Roth catch-up for high earners over $145,000 (2026), expanded long-term part-time employee tracking (2025), student loan matching (2024), emergency savings accounts (2024), and automatic portability (2025). Each requires plan administration software updates, payroll integration changes, and updated compliance testing routines.
How does the 2026 Roth catch-up requirement affect TPA systems?
Starting January 1, 2026, employees earning $145,000 or more must make catch-up contributions as Roth (after-tax) only. TPA systems need to track prior-year compensation, apply the income threshold, route catch-up contributions to the correct Roth account, coordinate with payroll providers for proper withholding, and update compliance testing to distinguish mandatory Roth catch-ups from elective deferrals.
What TPA IT infrastructure changes does SECURE 2.0 require?
SECURE 2.0 creates additional data processing, storage, and integration demands for TPAs. Systems must handle new data fields for LTPT tracking, emergency savings accounts, and student loan matching. Payroll integrations need updates for auto-enrollment defaults and Roth catch-up routing. Compliance testing software requires updates for new safe harbor provisions. File transfer protocols with recordkeepers need to accommodate new transaction types. All of these changes increase cybersecurity exposure as more data flows between more systems.
How TPAIT Supports SECURE 2.0 Readiness
TPAIT's TPA IT services are built around the reality that retirement plan technology is not static. Our team has nearly two decades of experience managing TPA IT infrastructure through major regulatory changes—including PPA, MAP-21, the original SECURE Act, and CARES Act implementations. We understand that SECURE 2.0 changes don't happen in isolation; they intersect with your existing plan document systems, compliance testing calendars, payroll integrations, and recordkeeper file transfers.
We help TPAs plan system updates, coordinate with software vendors on patch deployments, test new integrations in staging environments before production rollout, and maintain the cybersecurity controls needed to protect the additional data flows SECURE 2.0 creates. When your compliance team needs to know whether your systems are compliant with the Roth catch-up requirement now in effect—or ready for the next wave of provisions—they get a definitive answer, not a hedge.