Can I change the start date of our 401(k) plan?
Updated over a week ago

If your plan’s effective date for deferrals (start date) has not passed yet, you may be able to change the start date. However, there are several factors that dictate when your plan can or must begin.

Moving your start date forward

Plans starting in less than 30 days

If your plan is supposed to start in less than 30 days, you cannot move the start date sooner. This is because the IRS requires employers to give their employees automatic enrollment notices at least 30 days before the plan begins.

Our system will generate the earliest available start date based on the payroll schedule you provided during plan setup to meet the 30-day notice period required.

Plans starting in more than 30 days

If your start date is more than 30 days out as selected in plan setup, you may be able to move it sooner. The earliest available date you can move it forward will depend on the required 30-day notification window.

Moving your start date back

You can push your plan start date back in most scenarios, provided the effective date to start deferrals under the plan has not passed. However, if you are implementing a new safe harbor plan, you will need to do so before the October 1 deadline for the plan to be eligible.

If notifications have already been sent to participants, we will send a manual email letting them know about the new plan start date.

Start dates for controlled or legally related groups

According to IRS regulation, all entities within a controlled group or a legally related group must be treated as a single entity for the purposes of employee benefits. As a result, all entities starting new plans must have the same start date. If you’d like to move the plan start forward or back, the change would need to apply to all entities within the group.

For Guideline plan purposes, the plan design and start dates must all be identical, as the plans must all be tested together for nondiscrimination testing. You can reach out to your dedicated Onboarding Specialist to see if you may change the start date for all of the related entities.

How to request a start date change

If you have a dedicated Onboarding Specialist, you can email them directly to see if it’s permissible to change your plan’s start date. If so, they will make a plan amendment and the trustee will need to sign off on it.

If you do not have a dedicated Onboarding Specialist, you can email to request a start date change. An Onboarding Coordinator will be able to assess if the adjustment is permissible and publish a task on the trustee’s dashboard for the plan amendment approval.

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