Siebert Blog

When compliance becomes a structural challenge

Written by Siebert Financial | February 27, 2026

For many plan sponsors, regulatory compliance has shifted from a periodic obligation to a continuous operational challenge. The implementation of SECURE Act 2.0, layered on top of existing ERISA requirements and evolving participant expectations, has increased both the volume and complexity of retirement plan administration.

Industry coverage consistently indicates that small and mid-sized employers are disproportionately affected. Managing staggered effective dates, coordinating across recordkeepers, payroll systems, and advisors, and interpreting evolving guidance now requires ongoing attention rather than episodic review.

As a result, compliance is no longer a background function. It has become a core component of plan governance.

From reactive oversight to durable governance

Historically, many plan sponsors focused on meeting baseline compliance requirements and addressing issues as they emerged. That reactive model is increasingly misaligned with the current regulatory environment.

SECURE Act 2.0 introduced dozens of provisions that require judgment, prioritization, and sequencing rather than simple execution. Decisions around plan design, participant communication, and operational readiness are now interdependent.

When governance frameworks are not designed to absorb complexity, administrative effort increases, decision-making slows, and fiduciary risk becomes harder to manage consistently. In this context, effective oversight depends less on individual expertise and more on repeatable structures and clear accountability.

Why simplification supports better outcomes

Simplification is often misunderstood as reducing rigor. In practice, it enables rigor by making complex systems manageable.

Plan sponsors face real constraints on time, staffing, and specialized knowledge. Without structured processes, complexity tends to surface as manual work, fragmented decision-making, and inconsistent documentation.

Sponsors that prioritize simplification focus on:

  • Standardizing recurring processes and decisions
  • Using technology to monitor requirements, eligibility, and deadlines
  • Clearly defining roles across internal teams and external partners

These steps do not remove regulatory obligations. They reduce friction, support consistency, and allow governance bodies to focus on higher-impact decisions related to plan effectiveness and participant outcomes.

The expanding role of partners and infrastructure

As plan complexity grows, many sponsors are reassessing how responsibilities are allocated between internal teams and external providers.

Industry surveys indicate increased reliance on specialized advisors and outsourced governance support. The value of these relationships lies not only in technical expertise, but in their ability to translate regulatory requirements into operationally feasible solutions.

Effective partners help sponsors:

  • Assess which regulatory changes are relevant to their workforce
  • Anticipate downstream operational impacts before adopting plan design changes
  • Maintain documentation aligned with fiduciary standards

Importantly, outsourcing does not eliminate fiduciary responsibility. Sponsors retain oversight obligations and must evaluate recommendations within the context of plan objectives and participant needs.

Note: Professional advisory and outsourcing services can support plan governance, but plan sponsors remain responsible for fiduciary oversight and decision-making.

Building a practical simplification roadmap

For plan sponsors looking to move from reactive compliance to sustainable governance, simplification often begins with a structured review of current operations:

  1. Assess administrative pressure points
    Identify tasks that consistently require ad hoc intervention, manual work, or repeated clarification.
  2. Evaluate systems and integrations
    Determine whether existing platforms support current compliance needs or introduce friction across payroll, recordkeeping, and reporting workflows.
  3. Clarify escalation and decision frameworks
    Define which issues require committee review versus routine processing, and document how decisions are made and recorded.
  4. Review partner roles and accountability
    Ensure advisors, recordkeepers, and internal teams have clearly defined responsibilities, timelines, and handoffs.

These steps do not eliminate regulatory complexity, but they make it more manageable and predictable.

A more durable way forward

Regulatory complexity in retirement plans is unlikely to diminish. The more realistic objective is to build governance models that can adapt without disruption.

Sponsors who approach simplification as an ongoing capability rather than a one-time initiative are better positioned to manage change. By investing in structure, clarity, and the right partnerships, complexity becomes more predictable and less intrusive.

In this environment, simplification is not a tactical response. It is a strategic component of sustainable plan governance.

Explore 401(k) plan support at https://www.siebert.com/401k.

References
PlanAdviser — SECURE Act 2.0 Implementation Challenges
https://www.planadviser.com/secure-act-2-0-implementation-challenges/
BenefitsPRO — Plan sponsors struggle with SECURE Act 2.0 complexity (2024)
https://www.benefitspro.com/2024/01/15/plan-sponsors-struggle-with-secure-act-2-0-complexity/
PlanSponsor — Retirement Plan Governance Trends (2024)
https://www.plansponsor.com/retirement-plan-governance-trends-2024/
SHRM — SECURE Act 2.0 creates new burdens for plan sponsors
https://www.shrm.org/topics-tools/news/benefits/secure-act-2-0-creates-new-burdens-plan-sponsors
NAPA — Plan Sponsor Challenges Survey (2024)
https://www.napa-net.org/news-resources/articles/plan-sponsor-challenges-2024
 
Disclaimer:
The information provided here is for general informational purposes only and should not be construed as professional tax advice. Tax laws and regulations are complex and subject to change. For personalized advice tailored to your specific situation, it is always recommended to consult a qualified tax professional or accountant who can provide expert guidance based on your individual circumstances.