The Department of Labor has proposed new regulations updating ERISA electronic disclosure rules to implement the SECURE 2.0 requirement that participants receive periodic paper benefit statements. Under the proposal, defined contribution plans would be required to provide at least one paper statement annually, while defined benefit plans would have to provide a paper statement every three years. Participants could still elect electronic delivery, but paper would become the default baseline.
The retirement plan industry has spent years building efficient electronic delivery systems. Electronic disclosures are faster, easier to track, and far less expensive than traditional mail. Most participants already check their accounts online or through mobile apps. For many plans, electronic delivery is no longer an innovation — it is simply how communication works.
The Department of Labor’s concern is that electronic disclosures may not always reach participants effectively. While that concern is understandable, requiring paper statements feels like a regulatory solution looking backward instead of forward. The reality is that many participants ignore paper statements just as easily as they ignore emails. Paper does not guarantee engagement, and in many cases it simply creates more returned mail and more administrative work.
Plan sponsors will ultimately bear the burden of these new requirements. Paper statements mean additional costs, additional coordination with service providers, and another compliance obligation that must be monitored. Even a simple annual mailing becomes another task that must be documented and done correctly.
Plan providers will adapt, as they always do, but this proposal represents another reminder that retirement plan administration rarely becomes simpler.
Electronic delivery moved the industry forward. Mandatory paper statements move it back.
Plan sponsors should start preparing now, because if the proposal becomes final, paper statements will once again become part of everyday plan administration whether sponsors think participants want them or not.
