Updated SKILLs Suite, v2026.4, Release Notes
Release v2026.4 of the ERISA SKILLs Suite is available now, with content current through October 3, 2026.
Release v2026.4 has three significant improvements. It expands coverage of ERISA topics, it sharpens the technical detail across every practice area, and it reflects the updated guidance and case law issued since the last release (v2026.3, which was released in July).
Expanded coverage
We expanded coverage in several areas of ERISA law:
- Trump Accounts. Employer contribution programs under new Code §128, including the new W-2 reporting code and the August 2026 proposed regulations. Those regulations treat excludable contributions as wages for FICA and FUTA but not for income-tax withholding.
- Split-dollar life insurance. The economic-benefit and loan regimes, grandfather rules for older arrangements, the Sarbanes-Oxley bar on loans to public-company executives, and the §101(j) notice-and-consent rules. It also covers how split-dollar interacts with §457(f), §4958 and §4960.
- HRAs, ICHRAs and QSEHRAs. This includes excepted-benefit HRAs and the points where the rules are still unsettled.
- MEWAs. The bona fide association test, state regulation under ERISA §514(b)(6), Form M-1 and its two penalty tracks, and welfare-plan Form 5500 filings.
- Saver's Match. The federal matching contribution that replaces the Saver's Credit beginning in 2027, under Notice 2026-48. It covers how those deposits count toward plan limits and nondiscrimination testing.
- State mini-WARN acts. The new Nebraska, Washington and Ohio laws, alongside federal WARN.
- Also new: the PCORI fee, §414A automatic enrollment for newly established plans, and 403(b) multiple-employer and pooled-employer plans.
Sharper on the technical details
Most of the work in this release went into precision. It fills in the second-level rules that decide whether a general answer is the right answer for a particular plan. Some areas where we sharpened the SKILLs' focus:
- Retirement plans. The SECURE 2.0 Roth catch-up rule for higher earners, including the $150,000 threshold for 2026 and the exemption for the 403(b) 15-year catch-up. Top-heavy minimum contributions, excludable employees and the late 4% nonelective safe harbor. Universal availability in church versus governmental 403(b) plans. Long-term part-time service. RMD timing for beneficiaries.
- Health and welfare. The One Big Beautiful Bill Act's HSA changes, with the 2026 HSA and HDHP figures. Dependent care assistance program nondiscrimination testing.
- Executive compensation. §409A payment-timing rules. The proposed §457(f) regulations. §162(m) controlled-group aggregation. The §4960 excise tax on compensation at tax-exempt employers.
- Plan structure and corrections. SECURE 2.0's changes to family attribution under the controlled-group rules. The 2026 VCP user fees.
- Specialized areas. Withdrawal-liability procedure for multiemployer plans. ESOP fiduciary litigation.
Current through October 3, 2026
This release reflects the law and regulatory developments of the past several months, including:
- The IRS's September 2026 clarification that SECURE 2.0 amendments now run on two tracks. Discretionary amendments keep the existing deadlines. Required amendments, including the Roth catch-up, follow the Required Amendments List, and the Roth catch-up amendment is generally expected to be due by December 31, 2029.
- Cycle 4 dates for pre-approved defined contribution plans (Announcement 2026-15).
- The Fifth Circuit's en banc decision in TMA III on the No Surprises Act's qualifying payment amount methodology, and the end of the related enforcement relief on October 1, 2026.
- Proposed §129 dependent care nondiscrimination regulations, and the FAQs Part 74 guidance on wellness program rewards.
- Notice 2026-49 on direct rollovers, PBGC's attrition-event waiver, and a series of appellate decisions on plan forfeitures and fiduciary prudence.
What remains unchanged
The Suite is still twenty-eight SKILLs that you install in your own Claude account. It still names a judgment call as a judgment call instead of answering it. And it still tells you its release date whenever currency matters.
Updating
If you hold a license to a prior release, you can update at half the current license price for your tier. That rate never expires. See the SKILLs Suite for details.
This post is general information about technology and process, not legal advice. Questions requiring legal judgment should be directed to qualified ERISA counsel of your own choosing.