Connecticut Expands Compliance and Enforcement for MyCTSavings Retirement Program

29 Aug

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Update Applicable to:Effective Date
All Employers with 5 or More EmployeesJuly 1, 2025


What happened?

On June 9, 2025, Connecticut Governor Ned Lamont signed Public Act No. 25-30 / S.B. No. 1221 into law, amending the state’s Retirement Security Program and strengthening enforcement of MyCTSavings, the state-run retirement savings plan for private-sector employees whose employers do not offer a retirement plan.


Overview:

Changes to MyCTSavings (Effective July 1, 2025)

  • Three-Strike Enforcement Process
    • Employers who fail to comply will receive:
      • First notice of noncompliance from the Comptroller
      • Second notice
      • Final notice
    • If noncompliance continues for 90+ days, annual penalties apply:
      • $500 for small employers (5–24 employees)
      • $1,000 for medium employers (25–99 employees)
      • $1,500 for large employers (100+ employees)
  • Mandatory Auto-Enrollment
    • Employers with five or more employees must:
      • Enroll employees in MyCTSavings, or
      • Certify that their own retirement plan meets state standards.
    • Default contributions follow federal IRC §414A(b)(3)(A):
      • Minimum 3% contribution rate.
      • Automatic annual increase up to 10–15% unless the employee opts out.
  • Federal Saver’s Match Integration: The Comptroller must ensure participant accounts can receive federal Saver’s Match contributions for eligible low-income workers.


Clarifications and Additions

  • Contribution Defaults for New Participants: For employees enrolled on or after July 1, 2025, default contributions follow IRC §414A(b)(3)(A), with automatic escalation unless opted out.
  • Personal Care Attendants as Covered Employees
    • Starting July 1, 2026, personal care attendants are covered if:
      • Employed for at least 30 days.
      • Are 19 years or older.
      • Perform services under Section 31-222
    • Individuals receiving services from PCAs under state-funded programs will be considered qualified employers.
  • Enforcement Process – Clarified Structure: The law now clearly defines the three-step enforcement process, ensuring transparency and consistency in compliance actions.


Additional Information:

What Remains the Same

  • Applies to employers with 5+ employees who paid at least $5,000 in wages to five or more workers.
  • Employees become eligible after 120 days and must be at least 19 years old (except personal care attendants)
  • Default contribution rate remains 3% unless the employee elects otherwise.
  • Employers are not required to contribute to accounts or collect program fees.
  • Employers with qualifying plans (e.g., 401(k), 403(b), SIMPLE, SEP) are exempt from enrollment and information requirements.


Historical Context

  • Program Launch: March 24, 2022.
  • Initial Requirement: Employers with 5+ employees must register with the Comptroller’s Office to enroll or certify an existing plan.
  • Account Type: Roth IRA, funded via payroll deductions; accounts are portable, and employees may opt out or re-enroll at any time.


Source References

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This communication is intended solely for the purpose of conveying information. The present post might incorporate hyperlinks directing readers to websites managed by third-party entities. The inclusion of any links within this communication is meant to serve as points of reference and could encompass opinion articles from various law firms, articles from HR associations, official websites, news releases, and documents of government agencies, and other relevant third-party sources. Vensure has no authority over these external websites and bears no responsibility for their content. Furthermore, Vensure does not endorse the materials present on these websites. The contents of this communication should not be interpreted as legal advice or as a legal standpoint concerning specific facts or scenarios. Nor should it be deemed an exhaustive compilation of facts potentially pertinent to federal, state, or local laws. It is strongly advised that employers solicit legal guidance from an employment attorney when undertaking actions in response to any legal updates provided. This is due to the possibility of future alterations occurring in federal, state, and local laws, regulations, as well as the directives and guidelines issued by governing agencies. These changes may transpire at any given time, potentially rendering certain portions of the content within this update void or inaccurate.

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