SECURE 2.0 in 2026: What DFW Employers Must Change in Their 401(k) This Year

For DFW business owners, 401(k) plans have become more than a retirement benefit. They can play an important role in attracting employees, retaining key talent, and helping business owners build long-term wealth.

But, just like everything else in life, retirement plan rules continue to evolve. The SECURE 2.0 Act introduced a long list of changes affecting employer-sponsored retirement plans, and 2026 brings several important considerations for businesses with 401(k) plans.

For Dallas-Fort Worth employers, the question is not simply, “What does SECURE 2.0 require?”. It’s also, “Which changes apply to our plan, and are we taking advantage of the opportunities that could benefit our employees and our business?”.

Here are the key areas employers should review in 2026.

1. Review your automatic enrollment requirements

One of the most significant SECURE 2.0 changes is the requirement for certain newly established 401(k) plans to automatically enroll eligible employees.

For plans established after December 29, 2022, SECURE 2.0 generally requires automatic enrollment and automatic escalation for plan years beginning after December 31, 2024. There are exceptions for certain small businesses, new businesses, governmental and church plans, collective bargaining arrangements and other eligible plans.

For plans subject to the requirement, employees generally must be automatically enrolled at a contribution rate between 3% and 10%, with automatic increases of 1 percentage point each year until the contribution rate reaches at least 10% but no more than 15%. Employees must still be allowed to opt out or change their contribution rate.

That means an employer that established a new 401(k) plan in recent years should confirm that its payroll system, plan document and employee communications are operating consistently with the automatic enrollment provisions.

For established DFW companies, this may not mean making a change to an existing plan. However, it is worth confirming whether your plan falls under the SECURE 2.0 requirements or qualifies for an exception.

2. Make sure your plan can handle the 2026 contribution limits

The IRS increased the 401(k) employee contribution limit to $24,500 for 2026, up from $23,500 in 2025.

Employees who are age 50 and older can generally contribute an additional $8,000 in catch-up contributions, bringing the potential total to $32,500.

SECURE 2.0 also created an additional/higher catch-up contribution limit for employees who are between the ages of 60 and 63. For 2026, this additional catch-up limit is $11,250, meaning an eligible employee could potentially contribute up to $35,750 through regular and catch-up contributions.

Employers should make sure their payroll and recordkeeping systems are using the correct limits and that employees receive accurate information during enrollment and throughout the year.

This can be particularly important for highly compensated employees and business owners who want to maximize retirement plan contributions while staying within the applicable limits.

3. Prepare for the Roth catch-up contribution requirement

One of the biggest SECURE 2.0 changes is the new Roth catch-up requirement for higher-income employees.

Beginning in 2026, participants who are eligible to make catch-up contributions and whose prior-year FICA wages from the plan sponsor exceeded $150,000 must make their catch-up contributions as Roth contributions if the plan offers a Roth feature.

For example, imagine a DFW company has an employee who earned $175,000 in W-2 wages in 2025 and will be eligible for catch-up contributions in 2026. If that employee wants to contribute above the regular $24,500 limit, the catch-up portion generally needs to be treated as a Roth contribution.

This creates an important payroll and plan-administration issue. Employers need to be able to identify employees subject to the rule, as well as ensure their payroll and recordkeeping systems properly handle the contributions.

The IRS issued final regulations in 2025, and the final regulations generally apply to contributions in taxable years beginning after December 31, 2026, while allowing plans to implement the requirements earlier under a reasonable, good-faith interpretation. The IRS also states that the administrative transition period generally ended December 31, 2025.

In other words, 2026 is a year employers should be actively working with their recordkeeper, payroll provider and plan professionals to make sure the Roth catch-up process is functioning correctly.

4. Don’t overlook the new paper benefit statement requirement

Another SECURE 2.0 provision taking effect for plan years beginning after December 31, 2025 involves participant benefit statements.

Generally, defined contribution plans must provide at least one pension benefit statement in paper format each calendar year, subject to specific exceptions and electronic delivery rules.

The Department of Labor has issued guidance addressing the new requirement, which means employers and plan administrators should confirm that their participant communication process complies with the rules for 2026.

For employers that have moved almost entirely to electronic retirement plan communications, this is an easy requirement to overlook.

Your plan’s recordkeeper may handle much of the process, but employers should still confirm who is responsible for satisfying the requirement.

5. Review whether optional SECURE 2.0 features could improve your plan

SECURE 2.0 isn’t just about compliance. It also gives employers new tools that can make their retirement plans more attractive to employees.

For example, employers can choose to offer matching contributions based on qualified student loan payments. This can be particularly appealing for younger employees who are balancing retirement savings with student debt.

Employers can also provide certain small financial incentives for employees who elect to contribute to a retirement plan. These incentives can be worth up to $250 and cannot be paid from plan assets.

Other optional features include pension-linked emergency savings accounts and certain Roth treatment options for employer contributions.

For a DFW company competing for professionals in a tight labor market, these features may be worth considering. A retirement plan doesn’t have to be a one-size-fits-all benefit. The right combination of features can help an employer differentiate its benefits package while supporting employees at different stages of their financial lives.

6. Look beyond compliance and evaluate the plan itself

SECURE 2.0 compliance is only one piece of a well-designed retirement plan.

For business owners, 2026 is also a good time to step back and ask whether the company’s 401(k) is actually accomplishing what it was designed to do.

  • Are employees participating?
  • Are they contributing enough to make meaningful progress toward retirement?
  • Is the employer match competitive?
  • Are plan fees reasonable?
  • Does the investment lineup provide appropriate choices without being unnecessarily complicated?
  • Is the plan structured in a way that works well for the company’s owners and highly compensated employees?
  • And are there opportunities to use the plan more effectively for business owners who want to maximize retirement savings?

These questions can be especially important for successful privately held businesses throughout Southlake, Westlake, Frisco, Plano and the broader DFW area. A growing company may outgrow the retirement plan it originally established when it had fewer employees and a different compensation structure.

7. Coordinate your 401(k) with your broader tax strategy

For business owners, retirement planning and tax planning are closely connected.

The 2026 401(k) contribution limits create additional opportunities for employees to save, while employer contributions can also play an important role in the overall compensation and tax strategy of a business.

For example, a business owner may want to evaluate whether a traditional 401(k), safe harbor 401(k), profit-sharing arrangement or another retirement plan design makes the most sense based on the company’s profitability, employee demographics and owner’s goals.

This is where it can be helpful to look at the 401(k) as part of the company’s broader financial plan rather than treating it as simply an employee benefit.

A plan that looks inexpensive or straightforward on paper may not necessarily be the most effective structure for the business owners or their employees.

A 2026 401(k) checklist for DFW employers

If you sponsor a 401(k) plan, consider reviewing the following this year:

  • Confirm whether your plan is subject to SECURE 2.0’s automatic enrollment requirements.
  • Verify that 2026 contribution limits are properly reflected in your payroll system.
  • Confirm that employees ages 60–63 can take advantage of the higher $11,250 catch-up limit.
  • Identify employees who may be subject to the Roth catch-up requirement.
  • Confirm that your recordkeeper and payroll provider can properly process Roth catch-up contributions.
  • Review your participant communication and paper benefit statement procedures.
  • Determine whether any optional SECURE 2.0 provisions could improve your employee benefits package.
  • Review plan fees and investment options.
  • Consider whether your current plan design still makes sense as your business has grown.
  • Coordinate retirement plan decisions with your company’s broader tax and financial planning strategy.

The bottom line

SECURE 2.0 is not a requirement for every employer to completely redesign its 401(k). Instead, it is a collection of changes that affect different plans at different times.

For DFW employers, 2026 is an important opportunity to make sure the plan is operating correctly, particularly around contribution limits, Roth catch-up contributions, participant communications and any automatic enrollment requirements that apply.

It is also a good time to look beyond compliance. The best retirement plan is not necessarily the one with the fewest changes. It is the one that fits the company’s goals, supports employees and works alongside the owner’s broader tax and wealth strategy.

If your business sponsors a 401(k), a review with your financial advisor, CPA, third-party administrator and recordkeeper can help identify both compliance issues and opportunities to make the plan more effective.