• On May 12, 2026, the DOL announced temporary enforcement relief for retirement plan administrators that make good faith efforts to follow the new paper pension benefit statement rules.
• The policy allows plan administrators to rely on reasonable interpretations of the proposed rules until the DOL issues final guidance.
• Plan sponsors using electronic delivery may want to consider giving newly eligible participants an initial paper notice about their right to request paper documents.

Section 105(a)(2) of ERISA through Section 338(a) of the SECURE 2.0 Act of 2022 (SECURE 2.0) requires that defined contribution plans furnish at least one pension benefit statement on paper in any calendar year and that defined benefit plans generally must furnish at least one paper pension benefit statement every three calendar years. Subparagraph (E) requires that statements be provided on paper at least once per year by defined contribution plans and once every three years by defined benefit plans. The paper benefit statement requirement added by SECURE 2.0 is effective for plan years beginning after December 31, 2025.

Prior to SECURE 2.0, the EBSA had provided two safe harbors for compliance with the pension benefit statement requirements. The 2002 Electronic Disclosure Safe Harbor permits the statements to be provided electronically to participants whose integral work duties put them in a position to effectively access electronic disclosures and to participants who affirmatively consent...

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