New York is moving forward with a state-sponsored retirement savings initiative that will impact many private employers beginning in 2026. The New York State Secure Choice Savings Program is designed to expand access to retirement savings by requiring certain employers to facilitate payroll-based contributions into individual retirement accounts (IRAs) for their employees.
With enrollment opening and deadlines approaching, businesses should evaluate whether they are subject to the requirements and what steps may be needed to comply.
Who Is Required to Participate?
The program applies to private-sector employers in New York that:
- Have been in business for at least two years
- Employed 10 or more employees in New York during the previous calendar year
- Do not offer a qualified retirement plan, such as a 401(k), 403(b), SEP IRA, or SIMPLE IRA
Employers with an existing qualified plan are not required to participate but may need to certify their exemption through the Secure Choice system.
Key Deadlines
Enrollment deadlines vary by employer size:
- March 18, 2026 – 30 or more employees
- May 15, 2026 – 15 to 29 employees
- July 15, 2026 – 10 to 14 employees
Employers are expected to receive notification from the state, but early preparation may help avoid delays.
How the Program Works
Eligible employees are automatically enrolled in a Roth IRA funded through payroll deductions, with a default contribution rate of 3% of gross wages. Employees may opt out or adjust their contribution level at any time.
Accounts are portable, allowing employees to continue contributing even if they change employers.
Employer Responsibilities
While the program limits employer involvement, certain administrative steps are required:
- Registering with the program
- Uploading employee census data
- Providing required employee communications
- Facilitating enrollment
- Processing and remitting payroll deductions
- Maintaining participation and contribution records
Employers do not sponsor the accounts, make contributions, manage investments, or act as fiduciaries. However, the program introduces new administrative and payroll requirements. Coordination with payroll providers may be necessary to ensure compliance.
For employees, automatic enrollment may reduce take-home pay unless they opt out or adjust contributions. Participation remains voluntary.
Planning Ahead
Employers should assess whether they are subject to the program or qualify for an exemption. Preparing payroll systems, gathering employee data, and monitoring communications from the state can help streamline the process.
Some employers may also consider whether establishing their own retirement plan is a more suitable alternative.
At LMC, we are monitoring developments related to the New York Secure Choice Program and can assist with understanding the administrative, payroll, and tax considerations involved. If you have questions about how these requirements may affect your business, please reach out to your LMC advisor.