Tina Anstett, J.D.
ERISA Strategist
Published:
The Department of Labor’s (DOL) proposed regulations implementing Section 338 of the SECURE 2.0 Act mark a meaningful shift in how retirement plan statements are delivered.
While electronic delivery (e-delivery) remains broadly permissible, the default for certain statements flips back to paper for newly eligible participants after December 31, 2025, with important nuances for defined contribution (DC) and defined benefit (DB) plans. Below are key takeaways, implications, and concrete steps advisors and plan sponsors should take.
Key takeaways
#1
SECURE 2.0 updates
SECURE 2.0 adds an annual paper statement requirement as an overlay to existing DOL e-delivery safe harbors.
#2
E-Delivery Updates
DOL updates e-delivery safe harbors; paper is default for annual statements unless participants opt in.
#3
Next Steps
DOL proposed rules issued Feb 25, 2026; sponsors should map affected populations and update onboarding.