DOL’s New Paper Statement Requirement Begins in 2026: Key Changes for Plan Sponsors

A significant shift in retirement plan disclosure rules is coming soon, and employers should begin preparing now. In response to new regulations included under the SECURE 2.0 Act of 2022, the Department of Labor (DOL) will require certain pension benefit statements be furnished to participants on paper, even for those who currently receive electronic disclosures. This mandate, which represents one of the most notable updates to ERISA’s disclosure framework in years, applies to plan years beginning after Dec. 31, 2025.

To support plan administrators implementing these changes, the DOL issued Field Assistance Bulletin (FAB) 2026-02, which provides temporary enforcement relief and clarifies how the new paper statement rules interact with existing electronic disclosure safe harbors. The Department also released a notice titled “Requirement to Provide Paper Statements in Certain Cases – Amendments to Electronic Disclosure Safe Harbors,” outlining proposed updates to the 2002 and 2020 electronic delivery rules.

Together, these developments mean plan sponsors, administrators and recordkeepers will need to adjust their communication processes and prepare for increased paper mailings.

What SECURE 2.0 Requires

Beginning in 2026:

• Defined contribution (DC) plans must provide at least one paper pension benefit statement every calendar year.
• Defined benefit (DB) plans must provide one paper pension benefit statement every three calendar years.

Note that these requirements apply to participants who previously defaulted to electronic delivery. The only exception is for participants who actively elect to receive all disclosures electronically.

Proposed Changes to Electronic Disclosure Rules

To align existing rules with SECURE 2.0, the DOL has proposed updates relating to participant notices and electronic disclosures.

• One Time Initial Paper Notice for Newly Eligible Participants: Starting Jan. 1, 2026, individuals who first become eligible for a plan must be provided with a one time initial paper notice before they are defaulted to electronic delivery. This notice must explain the participant’s right to opt out of electronic delivery while also meeting the requirements put forth by the 2002 electronic disclosure safe harbor. Once this notice is provided, plans may continue using electronic delivery except for the required annual or triennial paper statements as listed above.
• Updates to the 2020 Electronic Disclosure Safe Harbor: The DOL also proposes that participants must be able to request electronic delivery of any paper statement. As such, paper statements must now include instructions for requesting electronic delivery, as well as contact information for the plan administrator.

These changes are intended to preserve participant choice while ensuring compliance with SECURE 2.0’s paper delivery mandate.

Temporary Enforcement Relief

The DOL will provide a good-faith compliance period while the rules are being finalized. During this transition, the Department will not focus on enforcement so long as reasonable efforts are made to comply with the mandate. This relief acknowledges the operational changes required for recordkeepers and plan sponsors.

What Plan Sponsors Should Do Now

• Review disclosure procedures to ensure paper statements can be produced and mailed on schedule.
• Coordinate with recordkeepers to confirm systems can track delivery preferences and generate compliant statements.
• Update participant communications to explain the new paper statement requirement and how to opt into electronic delivery.
• Monitor final rulemaking, as the requirements may be revised before adoption.

The DOL’s new paper statement requirements reflect a broader policy goal: ensuring all participants, including those less engaged with electronic communications, receive essential retirement information in a clear and accessible format. Though the change may increase administrative burdens, early preparation will help employers transition smoothly.

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This newsletter is intended to provide general information on matters of interest in the area of qualified retirement plans and is distributed with the understanding that the publisher and distributor are not rendering legal, tax or other professional advice. Readers should not act or rely on any information in this newsletter without first seeking the advice of an independent tax advisor such as an attorney or CPA.