When must participants receive an SPD and other retirement plan notices?
Last updated October 2, 2026
New participants must receive the SPD within 90 days of coverage; updated SPDs follow amendments on ERISA's schedule. Layered on top are annual notices — 401(k) safe harbor, QDIA, automatic enrollment, participant fee disclosures — most clustering ahead of each plan year.
Retirement plans carry a heavier recurring notice load than most sponsors expect:
- SPD: within 90 days of a participant's coverage (120 days for a new plan); restated SPD every 5 years if amended, 10 years regardless; SMMs for material changes in between.
- Annual notices (typically 30–90 days before plan year start): safe harbor notice, qualified default investment alternative (QDIA) notice, automatic enrollment notice — as applicable to the plan's design.
- Fee disclosures: the participant-level 404a-5 disclosure annually plus quarterly statements of fees actually charged.
Recordkeepers generate most of these, but delivery responsibility is the plan administrator's. An annual notice calendar — what, who, when, how delivered, confirmation kept — turns the pile into a checklist and the checklist into evidence.
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