IRS Seeks Input on Matching Student Loan Payments with Retirement Plan Perks
Published Date: 1/23/2026
Notice
Summary
The IRS wants your thoughts on how it collects info about retirement plans, especially those that match your student loan payments. If you’re involved with these plans—like employers or employees—this could affect how info is shared and reported. Get your comments in by March 24, 2026, to help shape smoother, clearer rules without extra hassle or costs.
Analyzed Economic Effects
3 provisions identified: 2 benefits, 1 costs, 0 mixed.
Student Loan Payments Can Trigger 401(k) Matches
Under Notice 2024-63, employees who make qualified student loan payments (QSLPs) are included among those eligible for employer matching contributions to retirement plans. Plan sponsors will collect information to process claims for QSLP matches.
Employers Face Bigger Reporting Burden
The IRS is increasing the number of TD 9169 respondents to 87,500 and reports an increase in burden hours: TD 9169 rises by 124,250 hours and Notice 2024-63 adds 96,875 hours. The notice lists an estimated 475,000 responses, 28 minutes per response, and total annual burden hours of 221,125.
Required Notices Inform Employee Choices
TD 9169 requires notices under sections 401(k)(12)(D) and 401(m)(11)(A)(ii) to be provided to eligible participants so they know their rights and obligations under certain plans. The information collected (including under Sec. 1.401(k)-2(b)(3) and Sec. 1.401(k)-1(d)(3)(iii)(C)) will be used by employees to decide whether to participate, to file income tax returns, and by employers for hardship distribution decisions.
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