SECURE 2.0 IT Requirements for Third-Party Administrators

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.

Provisions Already in Effect (Through 2025)

Mandatory Automatic Enrollment

What it requires: For plan years beginning after December 31, 2024, new 401(k) and 403(b) plans established after December 29, 2022 must automatically enroll eligible employees at 3–10% of pay, rising 1% a year to at least 10% (capped at 15%). Employers with 10 or fewer employees, businesses less than three years old, church plans and governmental plans are exempt.

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: Since 2025, participants who reach age 60, 61, 62 or 63 during the year can make catch-up contributions up to the greater of $10,000 or 150% of the 2024 regular catch-up limit, indexed after 2025: $11,250 for 2025 and 2026 (opens in new tab).

TPA IT impact: Systems need age-based contribution limit tracking with a new, higher catch-up tier. Payroll integrations must apply the correct limit based on the age the participant reaches during the calendar 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: For plan years beginning after December 31, 2024, employees who work at least 500 hours in each of two consecutive years (reduced from three under the original SECURE Act) must be allowed to make elective deferrals.

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: Since December 29, 2023, SECURE 2.0 has allowed an automatic portability provider to move a default IRA created from an involuntary cash-out (balances up to $7,000) into the participant’s new employer plan unless the participant opts out. The law does not require any particular network, and DOL’s January 2024 rule implementing the provider exemption is still a proposal.

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. Incoming rollovers move money, so they deserve the same identity checks as distributions.

Employer Matching to Roth Accounts

What it requires: Since December 29, 2022, plans may let participants elect to receive matching and nonelective contributions as Roth contributions (taxable when made).

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.

2026 Provisions Now in Effect

Mandatory Roth Catch-Up for Higher Earners (Over $150,000)

What it requires: Since January 1, 2026, employees whose prior-year FICA (Social Security) wages from the employer sponsoring the plan were more than $150,000 — the indexed threshold that applies to 2025 wages, announced in IRS Notice 2025-67 (opens in new tab) — 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), which generally apply for taxable years beginning after December 31, 2026, with a reasonable, good-faith interpretation standard before then.

TPA IT impact: This is the most complex SECURE 2.0 IT change for TPAs. Systems must track prior-year FICA wages from the sponsoring employer to determine who exceeds the 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 wage 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.

Paper Benefit Statements

What it requires: For plan years beginning after December 31, 2025, defined contribution plans generally must provide at least one paper benefit statement a year, and defined benefit plans one every three years. DOL proposed amendments to its e-delivery safe harbors in February 2026 and, in Field Assistance Bulletin 2026-02 (opens in new tab), said it will not take enforcement action against administrators that comply in good faith with a reasonable interpretation while the rule is finalized.

TPA IT impact: Document generation, print/mail pipelines, and e-delivery election tracking all need to reflect this, including which participants have elected electronic delivery and when each paper statement was sent.

Provisions Coming in 2027 and Beyond

TPAs should begin planning IT infrastructure for the provisions still ahead. The Saver’s Match, a federal matching contribution deposited into participants’ retirement accounts, starts in 2027. The final Roth catch-up regulations generally apply for taxable years beginning after December 31, 2026, ending the good-faith period. And the required minimum distribution age rises to 75 in 2033.

Several earlier changes also keep generating system work. The involuntary cash-out limit rose from $5,000 to $7,000 for distributions after December 31, 2023, which adds default-IRA and portability volume. Pension-linked emergency savings accounts (PLESAs), optional since 2024, require separate sub-account tracking. Expanded self-correction under EPCRS, effective at enactment, requires audit trails that document each correction.

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.

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 leadership has nearly two decades of experience running 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.