Six Key Focus Areas for Plan Sponsors in 2026 – A Clear-Eyed View

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Retirement plan sponsors enter 2026 facing one of the most consequential years in recent ERISA history. Regulatory forces, market realities, participant expectations, and fiduciary exposure are all evolving simultaneously. SECURE 2.0 is moving from statute to operations. Cybersecurity threats continue to escalate. Retirement income solutions are transitioning from conceptual to operational. Investment governance is recalibrating to a new market environment. Meanwhile, fee scrutiny and documentation standards remain central to fiduciary protection, and discussions around private markets in defined contribution plans are becoming more common.

In this environment, fiduciaries face both risk and opportunity. Committees that succeed in 2026 will do so through disciplined governance, strong documentation, and thoughtful approaches to plan design and investment oversight. Below is a clear‑eyed view of the issues that matter most now, and the actions sponsors should consider.

1. SECURE 2.0: A Year of Operational Implementation

SECURE 2.0's most significant provisions take effect in 2026, prompting coordinated updates across payroll, human resources, recordkeeping, and plan administration. High‑earning participants must make catch‑up contributions on a Roth basis. Long‑term part‑time eligibility requirements demand revised hours tracking and enrollment workflows. These changes require enterprise‑level coordination and leadership attention, not routine administrative updates.

Recommended Committee Focus:

• Assign a single point of accountability for SECURE 2.0 readiness.
• Conduct control tests to verify Roth catch‑up processing accuracy.
• Confirm long‑term part‑time eligibility logic and document procedures.
• Ensure updates to plan documents, summary plan descriptions, and internal controls.

2. Cybersecurity: A Core Fiduciary Responsibility

Protecting retirement plan accounts from cyber threats is now a key fiduciary responsibility for plan sponsors. Hackers are using more advanced tactics, so keeping accounts safe requires teamwork between plan sponsors and participants. Regulators expect plan sponsors to monitor how vendors handle security, have a plan for dealing with security incidents, and help educate participants about protecting their accounts.

Recommended Committee Focus:

• Conduct an annual cybersecurity review of key vendors.
• Update and test the plan’s incident‑response protocol.
• Provide targeted participant education regarding account security.

3. Retirement Income and Decumulation: Moving from Concept to Core Strategy

With more participants relying primarily on defined contribution balances, plan sponsors are expected to support the transition from saving to spending. Retirement income strategies must be structured, intentional, and well‑communicated.

Recommended Committee Focus:

• Define a clear retirement income philosophy for the plan.
• Establish evaluation criteria for income solutions.
• Integrate retirement income concepts into participant communications.

4. Investment Governance: Aligning Policy with a New Market Environment

Shifting economic conditions and long‑term capital‑market expectations require committees to refresh their investment governance frameworks. Updated assumptions should inform rebalancing policies, glidepath suitability, and diversification.

Recommended Committee Focus:

• Update long‑term capital‑market assumptions in the investment policy statement.
• Review the suitability of the target‑date strategy.
• Evaluate the investment lineup for appropriate diversification. 

5. Fees, Benchmarking, and Documentation: The Foundations of Fiduciary Protection

Fee oversight remains a cornerstone of fiduciary responsibility. Committees must evaluate recordkeeping fees, investment expenses, and advisory costs while ensuring decisions are thoroughly documented.

Recommended Committee Focus:

• Complete a full fee benchmark.
• Review share class selection and revenue arrangements.
• Strengthen meeting minutes and consolidate the fiduciary file.

6. Private Markets in Defined Contribution Plans: Curiosity with Caution

Interest in private markets within defined contribution plans is rising. These asset classes introduce operational and fiduciary complexities that must be evaluated with rigor. A thoughtful, documented approach is essential.

Recommended Committee Focus:

• Establish a formal position on private markets.
• If exploring, define guardrails and document due diligence.
• Ensure participant communication remains clear and accessible.

The Leadership Mindset for 2026

What will distinguish high‑performing fiduciaries in 2026 is clarity, discipline, and documentation. Committees should approach SECURE 2.0 implementation proactively, reinforce cybersecurity oversight, advance retirement income strategy, refresh investment governance, strengthen documentation, and thoughtfully evaluate emerging opportunities.

A disciplined governance process will help ensure the plan remains a source of financial security and confidence for employees in the years ahead. If your committee is seeking guidance on navigating private markets in defined contribution plans, SECURE 2.0 implementation, or enhancing fiduciary processes, Highland Consulting Associates is here to help. Contact Bill Meerman at 440-808-1500 to discuss how our experienced team can support your organization’s goals with clarity and confidence.

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Highland Consulting Associates, Inc. is a registered investment adviser. Information presented is for educational purposes only and is not intended to make an offer of solicitation for the sale or purchase of specific securities, investments, or investment strategies. Investments involve risk and unless otherwise stated, are not guaranteed. Be sure to first consult with a qualified financial adviser and/or tax professional before implementing any strategy discussed herein. Past performance is not indicative of future performance.