ICYMI: New Jersey Decreased Retirement Savings Requirement from 25 to 10 Employees
New Jersey has expanded its state-facilitated retirement program, RetireReady NJ, which may impact dental practices that do not currently offer a retirement plan.
What’s changing?
The State has amended the New Jersey Secure Choice Savings Program Act (P.L. 2019, c.56; N.J.S.A. 43:23-15 et seq.), reducing the employer threshold from 25 employees to 10 employees as part of an expanded rollout of the program.
Who may be affected?
Once fully implemented, the requirement will apply to employers that:
Have 10 or more employees
Have been in business for at least two years
Do not offer a qualified retirement plan (e.g., 401(k), SEP, SIMPLE IRA)
Important:
The law defines “employee” broadly and does not distinguish between full-time and part-time staff
Part-time employees count toward the 10-employee threshold and are generally eligible for participation
How do I count employees? (Example)
Example Practice (meets threshold):
5 full-time employees
3 part-time hygienists
2 part-time front desk staff
👉 Total = 10 employees is Covered
Example Practice (below threshold):
4 full-time employees
3 part-time employees
👉 Total = 7 employees is not covered (at this time)
Rule of thumb:
If they are on your payroll and receiving wages, they likely count.
What is required?
Covered employers must either:
Offer their own qualified retirement plan, or
Facilitate employee participation in the State’s RetireReady NJ program through payroll deduction IRAs
Key clarifications for dental practices
Employers are not required to contribute to employee accounts
Employees are automatically enrolled but may opt out at any time
The program is not considered an employer-sponsored retirement plan
Employers act as a facilitator of payroll deductions only
What should your practice do now?
Confirm your employee count, including part-time staff
Determine whether you already offer a qualified retirement plan
* If yes then you are generally exempt, but may need to certify that exemption
If no plan is offered → begin evaluating:
* Whether to adopt your own retirement plan, or
* Use the State RetireReady NJ program
Coordinate with your payroll provider (e.g., ADP, Paychex), accountant, and office manager
What happens if a practice does not comply?
The law includes a phased enforcement structure:
Initial non-compliance may result in a warning
Continued non-compliance may lead to per-employee financial penalties over time
Enforcement timing will depend on the State’s implementation schedule
Why this matters for dental practices
Many small and mid-sized practices may newly fall into the 10+ employee category, particularly when including part-time staff. Practices that have not previously offered retirement benefits may now need to implement a compliant option.
What to watch for next
The State has not yet released specific compliance deadlines for employers with 10 or more employees. Implementation will occur on a phased basis, and employers can expect advance notice and a defined compliance window before enforcement begins.
Bottom line
If your practice has 10 or more employees (including part-time staff) and does not offer a retirement plan, you should begin preparing now for a new compliance requirement.
Coordinate with your payroll provider, accountant, and office manager. NJDA will continue to monitor implementation and provide updates as additional guidance becomes available.
For more information, visit: RetireReady.nj.gov
