Just when retirement plan sponsors thought disclosure rules couldn’t get any more convoluted, the Department of Labor has offered temporary relief on SECURE 2.0’s paper statement requirements. For anyone keeping score at home, Congress passed a law requiring certain retirement plan benefit statements to be furnished on paper, even in an age where most participants check balances on their phones while pretending to listen in meetings. Then questions emerged about implementation, practical compliance concerns surfaced, and now the DOL has essentially said, “Make a good-faith effort while we sort this out.” If that sounds like the retirement plan equivalent of building the plane while flying it, welcome to employee benefits regulation.
Beginning with the 2026 plan year, defined contribution plans generally must provide at least one paper benefit statement annually, while defined benefit plans face a paper statement requirement every three years. On paper, that sounds manageable. In practice, it creates all sorts of operational questions because retirement plans rarely exist in a world where one rule applies cleanly without intersecting with five others. Some plans rely on electronic disclosure safe harbors. Some participants have affirmatively consented to electronic delivery. Some recordkeepers have systems built around digital communications because, you know, it’s 2026. So naturally, Congress decided to add a paper mandate back into the mix.
This is where plan sponsors need to stop assuming their vendors have everything under control. One of the great myths in this business is that if a recordkeeper handles participant communications, the compliance burden somehow magically transfers with it. It doesn’t. Somebody needs to know whether paper statements are being generated, how frequently, for whom, under what delivery rules, and whether the plan’s disclosure procedures align with the law. “I thought the recordkeeper had it” is not exactly a compelling defense if this becomes an issue later.
What makes this particularly amusing is that the retirement industry spent years moving away from paper for good reason. Electronic delivery reduces cost, improves efficiency, and reflects how most participants actually engage with their retirement accounts. Very few participants are eagerly waiting by the mailbox for a quarterly statement when they can check their balance between doomscrolling and ordering lunch. Yet here we are, reintroducing paper into a system that had largely modernized itself.
I understand the policy argument. Some participants prefer paper. Some may miss electronic notices or lack reliable digital access. Fair enough. But the way this gets implemented matters. Layering mandatory paper on top of existing electronic disclosure rules creates complexity, not clarity.
The lesson here is simple. Temporary enforcement relief is not the same thing as permission to ignore the issue. In the retirement plan world, “good-faith compliance” often translates to “you should already be figuring this out before someone else decides you didn’t.”
