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Defined contribution plan IRA Legislative updates

IRS Issues Notice on Saver's Match

The Internal Revenue Service (IRS) has issued Notice 2026-48, indicating that the Department of Treasury and IRS intend to issue proposed regulations regarding the Saver's Match contribution provision under SECURE 2.0. Pursuant to SECURE 2.0, for taxable years beginning after December 31, 2026, Treasury will make Saver's Match contributions equal to 50 percent of up to $2,000 of qualified retirement savings contributions made by certain low to moderate income individuals to an employer-sponsored retirement plan or IRA.

The Notice provides a discussion in Q&A format covering several issues. Of note, the guidance confirms that Saver's Match contributions will be claimed by an eligible individual by filing an income tax return and claiming the match on a separate Form 8880-A for that taxable year. The Notice further explains that Treasury and IRS are considering two methods for directing payment to a traditional or Roth IRA, with additional details coming later.

  • Directing payment to an already established traditional IRA would be facilitated again with Form 8880-A, including an IRA tracking number specific to that account registered with Treasury.

  • Directing payment to a Roth IRA would be similar to the process for a traditional IRA, except that Treasury would first establish a conduit traditional IRA and facilitate an immediate trustee-to-trustee transfer from the conduit IRA to the Roth IRA. This would be a Roth IRA conversion subject to tax and withholding.

With regard to directing Saver's Match contributions to a retirement plan electing to receive these contributions, Treasury and IRS are considering at least three paths forward.

  • Registration Path. Allow accepting retirement plans to provide registration information to Treasury and IRS to facilitate payment of Saver's Match contributions on behalf of an individual, whereby Treasury would establish a conduit IRA on behalf of the individual and immediately roll over the Saver's Match to the retirement plan.

  • Automatic Match Path. This process would allow retirement plan service providers to give plan and participant level information to Treasury and IRS to facilitate payment of Saver's Match contributions to an individual.

  • Rollover Path. This path would allow Treasury to establish a conduit IRA on behalf of an eligible individual. When the individual chooses a retirement plan for rollover from the IRA, the individual would give the IRS-provided Saver's Match confirmation number to the plan administrator, who would in turn provide information to Treasury about the individual and plan to facilitate the rollover.

Notice 2026-48 also includes model safe harbor notice language about the Saver's Match contributions that could be included in an annual notice for 2027. Additional Q&As cover reporting and miscellaneous details. Treasury and IRS are requesting comments no later than October 5, 2026, particularly around implementation methods and procedures.