Get In Touch With Us
As 2025 comes to a close, plan administrators should confirm compliance for the current year and prepare for changes effective January 1, 2026. Beyond the usual Form 5500 filing, here are five critical considerations to keep your plan audit-ready and compliant.
1. Apply Forfeitures Under SECURE 2.0
The SECURE 2.0 Act emphasizes timely use of forfeitures. For defined contribution plans, forfeitures must be applied promptly to reduce employer contributions or pay plan expenses. Unused forfeiture balances, especially older ones, are a growing focus for regulators and plaintiffs’ attorneys. Review your forfeiture account and ensure all balances are allocated by December 31, 2025, in accordance with your plan document and the new rules.
2. Review Remittance Timings for Employee Contributions
The Department of Labor requires participant contributions and loan repayments to be deposited into the plan as soon as they can be reasonably segregated from employer assets, not later than the 15th business day of the following month. This is not a safe harbor; if your payroll process allows faster segregation, contributions must be remitted sooner. Inconsistent remittance timing can trigger fiduciary concerns. Conduct a year-end review of your remittance patterns and document procedures for consistency.
3. Verify 2025 Compliance and Prepare for 2026 SECURE 2.0 Changes
Before year-end, confirm that your plan complied with 2025 requirements, such as expanded eligibility for long-term part-time employees (those with 500 hours in two consecutive years) and any discretionary amendments implemented during the year. Looking ahead to January 1, 2026, prepare for the mandatory Roth catch-up rule: employees earning more than $145,000 in FICA wages in 2025 must make all catch-up contributions on a Roth basis. If your plan does not currently allow Roth contributions, you must amend it or those employees will lose catch-up eligibility. Begin coordinating with payroll and recordkeepers now to identify affected participants and update systems.
4. Confirm Plan Amendments and Operational Alignment
If you made design changes during 2025—such as eligibility updates or contribution structure changes—ensure formal amendments are executed by December 31, 2025. Also verify that your Summary Plan Description (SPD) reflects these changes. Regulators expect plan documents to match operations, and discrepancies can lead to qualification failures.
5. Audit Payroll and Census Data Accuracy
Accurate payroll and census data are the foundation of proper plan operations. Errors in compensation definitions, hours worked, or participant demographics can lead to incorrect contributions and eligibility issues. Perform a reconciliation between payroll records and plan data before year-end to catch discrepancies early. This step is critical for smooth audits and compliance with nondiscrimination testing.
Year-end is the perfect time to address these compliance priorities. Proactive reviews not only help avoid costly penalties but also strengthen fiduciary governance. If you need assistance with an employee benefit plan audit or operational compliance review, our CPA team is here to help.
About the Authors
Eric Ritz leads the employee benefits plan practice within GreerWalker. His experience encompasses working with a diverse range of plans such as defined benefit plans, defined contribution plans, health and welfare plans, and ESOPs. Eric is also a seasoned presenter, regularly sharing his insights and knowledge at Employee Benefits Plan training sessions across the Carolinas
Jeremy Jacobs is an Assurance Senior Manager at GreerWalker. He serves a multitude of closely held businesses, demonstrating expertise within the manufacturing and distribution, restaurant, and dealership industries. Jeremy’s multifaceted skill set extends from offering assurance services to employee benefit plans.
About GreerWalker
GreerWalker LLP provides tax, accounting, and advisory services focused on the needs of privately-held middle-market companies and their owners throughout the US and around the globe.
Carolinas-Based
GreerWalker is proudly rooted in the Carolinas, where our deep regional experience and strong community ties have helped us become one of the largest CPA firms in the area. With over 150 associates, we are one of the ten largest CPA firms in our region.
Relationship-Driven
At GreerWalker, relationships are the foundation of everything we do. Outstanding service and innovative problem solving are our top priorities at every stage of our clients’ life and business. As an independent, owner managed firm we understand the needs of our clients. Through our affiliate, GreerWalker Corporate Finance LLC, and our strategic partner, Choreo, LLC*, we offer integrated solutions—from exit planning and M&A advisory to customized wealth planning—designed to grow with our clients and their goals.
U.S.-Delivered
While our roots are in the Carolinas, our reach extends across the United States and around the world. Each engagement is delivered by our U.S.-based team, providing clients with a consistent and familiar experience. Our global network offers additional expertise we can draw upon when client needs call for international coordination or specialized capabilities. This flexible model allows us to serve a diverse client base—domestic and international—with responsiveness and respect for regional preferences.
*Choreo, LLC is an investment adviser registered with the U.S. Securities and Exchange Commission (SEC). Registration as an investment adviser does not imply a certain level of skill or training of the adviser or its representatives.
For more information, please visit greerwalker.com.
