How the Saver’s Match Can Work for More Americans

Pew and the Bipartisan Policy Center urge Treasury, IRS to simplify the Saver’s Match for low-to-moderate-income workers

Speeches & Testimony October 5, 2026

Editor's Note: This was updated on November 4, 2026, to include the full comment letter.

On Oct. 5, The Pew Charitable Trusts and the Bipartisan Policy Center submitted a joint comment to the Treasury Department and the Internal Revenue Service in response to Notice 2026-48, which outlines how the federal government intends to issue regulations for the federal Saver’s Match program.

The Saver’s Match, which takes effect in 2027, will provide a federal matching contribution to eligible retirement savers. It has the potential to boost retirement security for millions of Americans with low to moderate incomes. Drawing on more than a decade of Pew research and input from a broad coalition of experts and stakeholders, the comment letter highlights opportunities to make the Saver’s Match program easier to access and more effective.

To accomplish those goals, the letter urges the Treasury and the IRS to make the new Form 8880-A free to file, streamline its calculations, and prepopulate it with data the IRS already receives, rather than asking filers to enter account numbers manually. The letter also encourages the agencies to favor more automated methods of delivering matching contributions, helping eligible savers avoid unnecessary complexity that could prevent them from accessing the benefit.

These decisions matter because even small obstacles can discourage participation among the households the Saver’s Match is designed to help. By focusing on practical design choices that reduce friction and protect families from unintended consequences—such as losing health coverage or other benefits—these recommendations aim to ensure that the Saver’s Match delivers on its promise to help more Americans save for their futures.

Read our full comment below.

October 5, 2026

Ms. Helen Morrison
Benefits Tax Counsel Office of Tax Policy
U.S. Department of the Treasury
1500 Pennsylvania Avenue, NW
Washington, D.C. 20220

Mr. Philip Lindenmuth
Associate Chief Counsel
Employee Benefits, Exempt Organizations, and Employment Taxes
Internal Revenue Service
1111 Constitution Avenue, NW
Washington, D.C. 20224

Submitted Electronically via www.regulations.gov

Re: Comments on Notice 2026-48, Notice of Intent to Issue Regulations with Respect to Saver’s Match Contributions

Dear Ms. Morrison and Mr. Lindenmuth:

On behalf of the Pew Charitable Trusts (Pew) and Bipartisan Policy Center (BPC), we appreciate the opportunity to respond to the request for comments on the Notice 2026-48 recently issued by the Department of the Treasury (“Treasury”) and the Internal Revenue Service (“IRS”).

Pew is a global, non-profit research and policy organization dedicated to informing the public and improving public policy with several initiatives focused on the financial health of American families. Specifically, Pew’s retirement savings project conducts research, provides technical assistance, and advocates for policies, resources, and practices that will enable all Americans to save for their future. ¹ BPC is a Washington, D.C.-based nonprofit that develops and advances pragmatic policies grounded in the best available evidence and achieved through genuine bipartisan cooperation.

We thank the Treasury and the IRS for the opportunity to comment. The Saver’s Match will encourage retirement plan participation and boost retirement savings by low- to moderate-income (LMI) working Americans, but there are significant challenges to an effective implementation and utilization.

Our comments are based on several sources. Pew’s retirement savings project has, since 2014, generated dozens of research publications on the barriers that prevent employers from offering retirement benefits to their workers, the challenges that Americans face in trying to save for a secure future, and the impacts of innovative policy interventions designed to increase retirement savings in the United States.

In addition, we have coordinated multiple convenings and working groups devoted to the implementation of the Saver’s Match. The working groups have met over the past 2.5 years to drill down on specific topics, including research, outreach, implementation challenges, and universal access. The working groups include stakeholders from over 50 organizations in industry, academia, think tanks, and the non-profit space. The comments contained in this letter represent the co-signing organizations' recommendations which have been informed by our research and discussions of the working groups, but do not necessarily represent the opinions of all the individual organizations that participated in the working groups. The following organizations asked to be listed as supporters of this work:

KC Boas, Retirement Initiative Lead, Aspen Institute Financial Security Program
Ellen Breslow, Senior Consultant, AKF Consulting Group
Kennan Cepa, Director of Research and Policy, SaverLife
Catherine Collinson, President, Transamerica Institute
Kelsy Mayo, Chief, Retirement Policy & Regulatory Affairs, American Retirement Association
Mark Iwry, Non-Resident Senior Fellow, The Brookings Institution
Tim Rouse, Executive Director, The SPARK Institute
Katie Selenski, Chief Strategy Officer, Defined Contribution Institutional Investment Association (DCIIA)

Recognizing that a great deal of work must follow, we invite experts from Treasury and the IRS to use the working groups as a sounding board for the detailed design and development work that is required for implementation. We believe a continuing dialogue would be useful to all involved. If you have any questions or would like more information regarding this letter, please contact Pew at [email protected] or BPC at [email protected].

Sincerely,

John C. Scott
Project Director, Retirement Savings Project
The Pew Charitable Trusts
[email protected] | 202.763.9031

Kimberly Olson
Senior Officer, Retirement Savings Project
The Pew Charitable Trusts
[email protected] | 202.540.6414

Shai Akabas
Vice President, Economic Policy
Bipartisan Policy Center
[email protected] | 202.204.2400

Comments

Although Notice 2026-48 focused primarily on how the Saver’s Match would move from Treasury to retirement accounts, we took a holistic approach to our comments, evaluating both the process and how an individual would interact with that process. Claiming and receiving the Saver’s Match needs to be as simple and automated as possible, because complexity and friction (i.e. processes that slow or prevent claiming) can cause even a highly motivated person to abandon a task. Where possible, we strongly recommend testing user processes and form designs, beginning in the first year, to identify where filers struggle or drop off, followed by participant interviews.

Filing for the Saver’s Match

Form 8880-A

Q.E-1 in the Notice indicated that IRS plans to create a Form 8880-A to claim the Saver’s Match. Assuming this form will be similar to Form 8880, IRS should consider the issues of cost, numeracy, and friction that already exist with Form 8880.

Cost to File: Filers who must pay extra to file forms associated with the Saver’s Match are less likely to claim it. Tax preparation software companies often charge extra for forms they consider “specialized” or “deluxe,” including the Form 8880, which serves to discourage low-income filers from using it to file for the Saver’s Credit. The IRS should ensure that Form 8880-A is included in all Free File options and aggressively promote its Free File options along with the Saver’s Match, as many eligible individuals also qualify for free filing. IRS Free File is available to taxpayers with an Adjusted Gross Income (AGI) of $89,000 or less in 2026,² which means that approximately 70 percent of tax filers could qualify based on AGI.³ In 2024, a report by the Treasury Inspector General for Tax Administration found that participation in IRS Free File averaged only three percent of eligible taxpayers during the processing years 2020 through 2024.⁴ Promoting Free File and ensuring that Free File users have a seamless experience filing the new Form 8880-A will ensure more eligible individuals can take advantage of the Saver’s Match.

Numeracy. Filling out Form 8880 requires a high level of ability to comprehend and work with numbers. Other tax programs like the Earned Income Tax Credit (EITC) have seen high rates of incorrect claims, most of which experts attribute not to fraud, but rather to innocent mistakes due to complicated filing processes.⁵ In its current version, the 8880 requires calculations and mathematical reasoning in lines 3, 5, 6, 7, 10, 11, and 12. Although each calculation on its own is fairly simple, the sheer quantity of calculations increases the risk of error—and given that each response is reliant upon accurate calculations from previous lines, one small error at any point could lead to an incorrect final filing. Pew recommends that the forthcoming Form 8880-A be rigorously reviewed and streamlined in terms of the mathematical calculations needed to complete the form.

Friction. Filing Form 8880 involves several steps that can be confusing or time-consuming, leading to tax filers not completing the form. Clearer instructions and fewer calculations would make the process smoother. It is likely that Form 8880-A will need to obtain the same information from lines 1 through 10 of the current Form 8880, with “specified early distributions” substituted for the disqualifying distributions on line 4. In addition, the Form 8880-A should include an option to make the applicable election where the credit total is greater than zero but less than $100. Pew recommends that, where possible, tax software and online filing tools should pre-populate the form with information based on data the IRS already receives, such as provider data, the Saver’s Match destination number, and contributions reported on W-2s and Form 5498. This would minimize the need for manual entry, making it easier for individuals to confirm or update details.

Additional information. Based on the process described in the Notice, a taxpayer will need to enter the Saver’s Match destination number they have received either from their provider or a government website.

Anytime a taxpayer is required to enter a number by hand, there is an increased probability for error. If asked to provide a Saver’s Match destination number, they may use Google or ChatGPT to find the number, transpose numbers, or leave the line blank. Instead of asking the individual to provide the destination number, we encourage Treasury and IRS to using existing data flows, such as those reported on Form W-2 and Form 5498, to establish a default destination for the match. The taxpayer could then be asked to confirm the destination, leading to fewer errors.
If establishing a default destination using existing data is not possible, we recommend that all registered plans and provider numbers are contained in a drop-down menu. The menu should be alphabetical by provider name (or the name the taxpayer is most likely to recognize, for instance, listing a state auto-IRA program by their program name) to assist the taxpayer with selecting the correct provider. This will reduce the likelihood of incorrectly entered numbers.

Form 1040 Non-filers

The Notice laid out a path to access the Saver’s Match for individuals who file a full Form 1040, but nothing for non-filers. In 2022, the Tax Policy Center estimated that nearly 30 million people in the U.S. had neither individual income nor payroll taxes. About 90 percent of households making less than $30,000 paid no federal income tax, as well as about half of those making between $30,000 and $60,000.⁶ Given that low-income households generally are the least likely to save for retirement, and that households making less than the standard deduction are not required to file a Form 1040 ($16,100 for individuals/$32,200 for married filing jointly in 2026), this group of non-filers would be disproportionately impacted by their exclusion from this match.⁷

To remedy this, Treasury and IRS should make available a simplified form for claiming the Saver’s Match, allowing people to certify that their income is below the filing threshold. For those not required to file a Form 1040, a streamlined option—like the IRS’s Non-Filer Sign-up Tool—could help.⁸ The IRS could also work with local organizations to help low-income individuals claim the matching funds. Promoting the Saver’s Match along with other tax benefits, like the Earned Income Tax Credit (EITC), could encourage more people to participate.

As another option, IRS could add a checkbox to Form 8880-A whereby individuals would attest that their AGI is below the threshold that requires them to file a Form 1040. There could be a formal attestation at the bottom of the form, to ensure that people only select the box if they truly do not need to file Form 1040, as well as an address that accepts Form 8880-A filings without an accompanying Form 1040.

Two notes:

EITC and other benefits: It is highly likely individuals claiming this matching contribution may qualify for other tax benefits, such as the EITC, that are not available except by filing Form 1040. A streamlined process for receipt of the Saver’s Match may want to provide information on how to access these other benefits directly to the individual and/or link to information about them.
Technical: Filing a Form 1040 ensures a tax return goes through all the existing fraud prevention measures; a separate filing mechanism would require a separate fraud prevention check. Furthermore, Section 6433(a)(2)(A) suggests that the claim will not be processed until after the return has been filed. Process and technical adjustments will likely be needed to prevent fraud if a more streamlined process is developed.

Directing Saver’s Match Contributions: Three Paths

Q&A.E-3 of the Notice laid out three potential paths Treasury could use to direct the Saver’s Match to individual accounts. Our comments on all three paths are as follows:

Rollover Path. Of the three potential paths, this is the least desirable due to friction and complexity for the applicant. The multi-step process of applying for the Saver’s Match, then waiting to receive a confirmation number from IRS that must be forwarded by the applicant to the retirement plan or provider all but ensures that many eligible tax filers will not receive the Saver’s Match because of missed steps and task abandonment. The one element of this path worth implementing in the final process is the use of a conduit IRA to roll-over the Saver’s Match into the destination account.
Automatic Match Path. This path most closely aligns with what Pew laid out in our Notice 2024-65 RFI response in 2024,⁹ using data that is already moving between retirement plans/providers and the government to match eligible individuals and their accounts, without requiring the individual to be involved in that process. In terms of reducing friction and complexity for the applicant, this path is best. However, the path lacks the conduit IRA to roll-over element present in both the Rollover Path and the Registration Path, which means that individuals would be subject to the Saver’s Match recovery tax. If Treasury and IRS choose to use the Automatic Match Path, either now or in the future, we recommend incorporating the conduit IRA into this process.
Registration Path. The path has moderate friction and complexity for the individual. If the individual is a W-2 employee contributing to an employer-sponsored retirement plan and their Saver’s Match destination number is printed on their W-2, filling out the 8880-A should be low effort. However, if the individual is contributing to an IRA either directly or through a state auto-IRA program, they will have difficulty locating the destination number, particularly since the Form 5498 is unlikely to be available during tax filing season. Use of the conduit IRA to roll-over the match is a positive for this path, as is eliminating the need for plans to make an amendment to accept the funds. We see this path as having the potential to work for most applicants, plans and providers, but we have some additional thoughts specific to this path below.

Registration Path: Withholding for a Roth Conversion

Q&A.E-2(b) of the Notice stated that a transfer from a conduit IRA to an individual’s Roth IRA is a Roth conversion and subject to withholding under section 3405; however, subjecting the Saver’s Match to withholding at the time of the conversion runs counter to the purpose of the program. Matching funds provide a monetary incentive for individuals to save for retirement, aligning with norms within the defined contribution industry. Reducing the net amount of matching funds that land in the retirement account will not only reduce the incentive to save but reduce the long-term effect of the match on asset accumulation.

Treasury and IRS should ensure the entire match reaches the Roth IRA, ideally through a default, no-withholding rule for these transfers. The individual should be given the option to choose to withhold, but in the absence of an affirmative selection, no withholding should apply to these transfers.

If a default rule is not possible, individuals should make an election on Form 8880-A with strong encouragement to decline immediate withholding, including a plain language description of the tax ramifications of withholding, for example:

Choosing to withhold taxes from your Saver’s Match is a “taxable distribution.” This means you are taking money out of your retirement account early to pay taxes owed. If you are under 59 ½ there is an additional 10% early withdrawal penalty for taking this action. To avoid the penalty, decline withholding.

Registration Path: Excluding Traditional IRAs from the conduit IRA system

We understand that the Registration Path would use the conduit IRA to move match money from Treasury to retirement plans (like 401ks) and to convert match money so it can be deposited into a Roth IRA. Selecting a Traditional IRA as the destination for the Saver’s Match money, however, will not use a conduit IRA. This direct transfer means that a Saver’s Match deposited into a Traditional IRA account will be subject to the Saver’s Match recovery tax if the individual makes a withdrawal from the account in the future.

The Tax Policy Center, in an examination of tax year 2020, found that 18.8 million taxpayers with income between $0-$50,000 had an IRA (Traditional, Roth, SEP, or SIMPLE) but just 0.9% of taxpayers in that income bracket were contributing to a Traditional IRA in 2020.¹⁰ The vast majority of Traditional IRAs are roll-overs from 401k accounts, not regular savings instruments. As noted in the introduction, simplicity will be key to ensuring eligible individuals can access the Saver’s Match. The more complex the details, the more likely we will see households choose not to apply for the funds. We recommend using the conduit IRA for all account types to reduce the need to message a separate set of rules and requirements for a relatively small pool of Traditional IRA contributors. If the only account type that will be subject to the recovery tax is Traditional IRAs, we recommend that the IRS and Treasury provide clear guidance to those account holders and the account service providers about the ramifications of future withdrawals.

Concerns About Interactions with Benefit Programs

Roth conversion as a taxable event

Use of the conduit IRA to move the money from Treasury into a Roth IRA solves many of the issues for Roth IRA savers that we noted in our Notice 2024-65 RFI response. We are grateful to Treasury and IRS for working to find a solution, particularly for savers in state auto-IRA programs. However, as we look at the potential downstream effects of a Roth conversion on LMI individuals, many of whom may be using public benefit programs, we want to alert Treasury and IRS to a new area of concern: public benefit cliffs.

The Saver’s Match was designed with a phase-out range to try to limit the impact of a benefit cliff. Benefit cliffs occur when an individual or family’s income rises above a cut-off threshold, triggering a partial or complete loss of benefits. Research from the Federal Reserve shows that people using public benefits and earning up to approximately $60,000 a year may encounter a benefit cliff if their income increases.¹¹

Take for example, healthcare. The Center for Budget and Policy Priorities states that “for the premium tax credit, most categories of Medicaid eligibility, and the Children’s Health Insurance Program (CHIP), all Affordable Care Act (ACA) marketplaces and state Medicaid and CHIP agencies determine a household’s income using MAGI.”¹²

Therefore, our concern with creating a taxable event of up to $1,000 for an LMI saver is that the event will increase their MAGI for the following year, potentially disqualifying the individual or family for needed benefits, like Medicaid or CHIP. These programs generally do not impose an asset test, but the Roth conversion will increase income for the purpose of MAGI.

For example, a family of four living in one of the 40 Medicaid expansion states has an annual income limit of $45,706 to qualify for Medicaid, calculated using MAGI.¹³ If this couple, married filing jointly, made $45,000 in income, saved $2,000 in a Roth IRA and received an $880 Saver’s Match (since their MAGI is within the phase-out range), they would be disqualified for Medicaid the following year, losing a benefit with a much higher dollar value than the $880 now deposited in their retirement account.

Even more concerning, income thresholds to qualify for public benefits can vary from state to state and program to program, further compounding the problem of explaining impact on an individual level for those in the target demographic for the Saver’s Match.

We ask Treasury and IRS to issue taxpayer-facing materials that communicate clearly about the potential ramifications of the conversion for individuals using public benefit programs, and to create model language for tax preparers, VITA sites, and Free File programs as well as stakeholders that work with populations that access public benefits at the state and federal levels.

Additionally, we recommend that Treasury evaluate ways to exclude Saver’s Match deposits from taxable income. The idea behind public benefit programs is to help low- to moderate-income households stabilize, then improve their situation. The Saver’s Match, as a new benefit program, is meant to improve the long-term financial stability of these households. The government should not force those same households to choose between having health care or food aid and receiving these matching funds.

Finally, the Saver’s Match statute does not appear to exclude the matching funds from calculations of asset limits for public benefit programs. Recipients of benefits (i.e., SSI, SNAP, TANF, etc.) are often subject to limitations on their total assets, in addition to limitations on their income. As retirement accounts grow over time, households may lose access to needed public benefit programs, even though they cannot or should not access those funds until retirement. We recommend a statutory amendment to remove the matching funds from the calculation of assets for federal public benefit programs.

Personal Responsibility and Work Opportunity Reconciliation Act (PRWORA) and the Saver’s Match

A footnote in Q.A-1 of the Notice states that the Justice Department’s Office of Legal Counsel has opined¹⁴ that the refunded portion of certain refundable Federal income tax credits, including the Saver’s Match, are federal public benefits within the meaning of the Personal Responsibility and Work Opportunity Reconciliation Act of 1996 (PRWORA), and that Treasury and IRS anticipate addressing the applicability of PRWORA to Saver’s Match contributions in forthcoming proposed regulations. Under this interpretation of PRWORA, aliens who are not “qualified aliens” would be ineligible for the Saver’s Match.

We are seeking clarification on who would no longer be eligible to claim the matching funds and/or matching contribution refund. In the Saver’s Match statute, the definition of eligibility uses tax-residency concepts (i.e., resident vs. non-resident alien). These definitions do not align precisely with PRWORA’s immigration status definitions (i.e., qualified alien vs. non-qualified alien). In order to clearly message eligibility and avoid potential future harm to individuals who meet the tax-residency designation, but not the qualified alien designation, we request that Treasury and IRS identify precisely who would no longer be eligible and communicate this information in all outreach to taxpayers, tax preparers, VITA sites, and organizations that work with immigrants or other non-US citizens.

Finally, as noted throughout this comment, increasing the complexity of applying for the Saver’s Match will decrease uptake. If a legal permanent resident (LPR), married filing jointly with their US citizen spouse filed for and received the Saver’s Match, could this be viewed as taking advantage of a federal benefit during a future naturalization case? What if the LPR did not file for the Saver’s Match, but the spouse did, using the combined MAGI of the couple to qualify? Uncertainty about whether someone qualifies or whether applying for a refundable tax credit could put their future naturalization in jeopardy due to the public charge rules could lead otherwise eligible individuals to miss out on these matching funds. Further clarity is needed to ensure that all eligible individuals can access the Saver’s Match and improve their long-term financial security.