Connecticut Retirement Mandate: MyCTSavings Explained
The Connecticut retirement mandate: who must register for MyCTSavings, the deadline, the penalties, how the auto-IRA works, and the 401(k) alternative.
Connecticut Retirement Mandate
Connecticut gives a covered employer with no plan of its own exactly two acceptable answers: register for MyCTSavings and run the payroll deductions, or certify that you already sponsor a qualifying plan. What the state program actually requires, what missing the deadline costs, how the auto-IRA behaves on a real paycheck, and when starting your own 401(k) is the better decision
A founder in Hartford forwarded me a letter from the state with the subject line rewritten in capitals and one question underneath it: does this mean I have to pay for everyone's retirement now. That was his honest reading of the notice, and it is the wrong reading, and the distance between those two interpretations is most of what this page is for.
The Connecticut retirement mandate does not ask you to fund anything. It asks you to pick one of exactly two acceptable answers: register for the state program and run the payroll deductions, or tell the state you already sponsor a qualifying plan of your own. There is no third answer where you read the letter, decide it does not feel urgent, and file it.
What follows is who the mandate covers, the deadline and the annual cycle behind it, what missing it actually costs, how the auto-IRA behaves on a real paycheck, and the honest comparison against starting a 401(k) instead. I build the people and records tooling for businesses without an HR department at FirstHR, and FirstHR is an onboarding and HR platform rather than a payroll or retirement plan provider. This is general information, not legal or tax advice.
What MyCTSavings Is
MyCTSavings is Connecticut's state-facilitated automatic enrollment Roth IRA program, administered by the Office of the State Comptroller for private sector employees whose employers do not offer a retirement plan. It is a savings vehicle the state runs and you plug into, not a plan you own.
The program sits inside the same family of state auto-IRA programs described in our overview of state retirement program mandates, and the Connecticut version is administered by the Comptroller rather than by a standalone authority (Office of the State Comptroller).
Two things about that structure matter commercially. The accounts belong to the employees, so they follow people to their next job. And because no employer money enters them, the program produces none of the goodwill a match produces, which is a fair reason to consider the alternative later on this page.
Whether the Mandate Applies to Your Business
The test is a snapshot, not a running count. Conn. Gen. Stat. 31-416 defines a qualified employer as an entity doing business in the state that employed five or more individuals in Connecticut on October first of the preceding calendar year and paid at least five of them taxable wages of not less than five thousand dollars during that year.
| Condition | What it actually means | Source |
|---|---|---|
| Five or more individuals employed in Connecticut | Measured on October first of the preceding calendar year, not on the day the letter arrives | Conn. Gen. Stat. 31-416 |
| At least five of them paid $5,000 or more | Taxable wages during that preceding calendar year | Conn. Gen. Stat. 31-416 |
| Private sector only | Federal, state, municipal and municipal housing employers are excluded | Conn. Gen. Stat. 31-416 |
| In existence throughout both years | An employer that did not exist for all of the current and preceding calendar year is outside the definition | Conn. Gen. Stat. 31-416 |
| No qualifying plan of your own | A plan or arrangement described in IRC 219(g)(5) removes the duty to enroll employees | Conn. Gen. Stat. 31-422 |
The employee side has its own definition and it is not about hours. A covered employee is someone employed by a qualified employer for at least one hundred twenty days, aged nineteen or older, performing services within the state, which means a long-serving part-time person is generally in and a brand new full-time hire is not yet. The full statutory text sits in the general statutes (Connecticut General Assembly), and the wider state picture is on our Connecticut compliance hub.
One dated expansion is worth knowing about. From July 1, 2026, the definitions reach personal care attendants and the consumers who receive their services under a state-funded program, with a thirty day service requirement rather than one hundred twenty.
The Deadline and the Annual Cycle
The original staged launch deadlines are long gone, and what remains is an annual cycle keyed to August 31. Employers that become newly covered are notified by the state and are expected to register or certify an exemption by that date, which for most businesses arrives the summer after they crossed the October first threshold.
Those last two numbers come straight from Conn. Gen. Stat. 31-422 and they are the ones small employers actually breach. Materials go to an employee within thirty days of hire or of becoming eligible, and automatic enrollment follows within sixty days of the materials, unless the Comptroller prescribes another period.
The practical failure mode is not defiance, it is drift. A business hires a fifth person in September, crosses the October first snapshot without registering the significance, hears nothing for ten months, then receives a notice in the summer and treats it as a solicitation. By then the clock has been running the whole time.
What Noncompliance Actually Costs
Connecticut replaced a weak enforcement mechanism with a real one. Public Act 25-30, effective July 1, 2025, moved the state from bringing civil actions to assessing civil penalties directly through the Comptroller, and the penalties repeat annually rather than landing once.
| Maximum civil penalty per year | Applies at | Trigger |
|---|---|---|
| Up to $500 | The smallest covered employers | Each year noncompliant for ninety calendar days or longer after the final notice |
| Up to $1,000 | Once you reach the twenty-five employee threshold | Same |
| Up to $1,500 | Once you reach the one hundred employee threshold | Same |
Two failures trigger the sequence, not one. Failing to enroll covered employees is the obvious one. Failing to transmit contributions you already withheld is the other, and it is the more dangerous of the two because withheld money that has not been remitted is an employee's money sitting in your account.
How the Auto-IRA Mechanics Actually Work
Understanding the mechanics is mostly about noticing how few of the decisions are yours. The state sets the default rate, the escalation, the account type and the investment default, and the employee controls everything else.
The escalation deserves a second look because it is the part employees ask about. A saver who never touches anything sees the deduction climb by one point every January until it reaches the cap, which is exactly the behavior Public Act 25-30 pointed at when it tied the default contribution level for savers enrolled from July 1, 2025 to Internal Revenue Code Section 414A(b)(3)(A).
The default investment is an age-appropriate target date fund under Conn. Gen. Stat. 31-423, with contributions initially held in a capital preservation portfolio before moving across. None of that is your selection or your recommendation, and saying so plainly when an employee asks is both accurate and protective.
What You Do on Payroll, and What You Never Do
Your entire operational role is roster hygiene plus a payroll deduction you did not set. Conn. Gen. Stat. 31-422 requires you to transmit a withheld contribution on the earliest date it can be transmitted, and no later than ten business days after it came out of the paycheck.
The right-hand column is the point of this page. Conn. Gen. Stat. 31-422 states that no employer shall be permitted to make a contribution to the program, which is stronger than saying contributions are optional. You are barred from putting money in, which is precisely why this arrangement is not the same thing as sponsoring a plan and does not carry the sponsor duties that come with ERISA-covered plans.
Practically, that means the questions employees bring you are not yours to answer. Whether to stay in, which portfolio to hold, whether a Roth is right for their tax position: all of it belongs to the program and to the employee's own advisor. Pointing at the program contact details is the correct answer, not a dodge.
Certifying an Exemption With Your Own Plan
Sponsoring a qualifying plan exempts you from enrolling employees, but it does not exempt you from responding. Conn. Gen. Stat. 31-422 removes the duty for an employer maintaining a retirement plan or arrangement described in Internal Revenue Code Section 219(g)(5), or another arrangement approved by the Comptroller, and the exemption is claimed rather than assumed.
Sponsoring a 401(k) Instead
The alternative to facilitating the state program is sponsoring your own plan, and the case for it is not compliance, it is capability. A 401(k) allows far higher deferrals than an IRA, permits an employer match, and behaves like a benefit rather than a payroll instruction.
The cost objection is weaker than it was. Under the federal startup credits, an eligible small employer can claim a percentage of qualified startup costs up to the greater of $500 or a formula amount capped at $5,000 per year for three years, with a separate credit of up to $500 a year for three years for adding automatic enrollment (Internal Revenue Service).
There is also a per-employee employer contribution credit for the smallest employers, worth up to $1,000 per participant in the first years and phasing down after that, which is the piece most owners have never heard of. The wider set of changes behind those credits is covered in our guide to the SECURE Act 2.0 for small employers.
Setting one up is a real project rather than a form, and the sequence, the deadlines and the provider decisions are laid out in our walkthrough of starting a 401(k) from scratch. Eligibility rules also decide the cost, and the long-term part-time rules mean part-time employees can become eligible sooner than owners expect.
Which Route Fits Your Business
Choose the state program if your goal is to satisfy the mandate at zero employer cost. Choose your own plan if your goal is a retirement benefit that does work for you in recruiting, retention and your own tax position.
| Factor | MyCTSavings | Your own 401(k) |
|---|---|---|
| Employer cost | None, and employer contributions are prohibited | Plan fees, administration, plus any match you choose |
| Employer contribution possible | No | Yes, including a safe harbor design |
| Contribution ceiling for savers | The IRA limit, which is materially lower | The much higher 401(k) deferral limit |
| Who is the plan sponsor | The state, not you | You |
| Fiduciary and investment selection | Handled by the state and its advisers | Yours, usually shared with a provider |
| Annual filings | None for the employer | Generally required once the plan reaches the filing thresholds |
| Recruiting value | Low, employees see a deduction | High, employees see money you added |
| Setup effort | Registration and roster upload | Plan document, provider selection, ongoing administration |
The two are not permanently exclusive. Plenty of Connecticut employers facilitate the state program for a year or two, then establish a plan once headcount and cash flow support it, and certify the exemption at that point. Treating the state program as a floor rather than a destination is a reasonable position, and it fits the wider way most small business benefits programs get built.
Where Connecticut Employers Get This Wrong
Assuming the exemption applies itself is first, and it is the most common. Sponsoring a 401(k) removes the duty to enroll employees, but the state has no way of knowing that until you certify, so an exempt employer that stays silent walks into the same notice sequence as one that ignored the mandate outright.
Reading the coverage test against today's roster is second. The test looks at October first of the preceding calendar year, which means a business that has since shrunk can still be covered and a business that has since grown may not be yet.
Treating remittance as a monthly chore is third. The statute wants withheld contributions transmitted on the earliest date possible and no later than ten business days after withholding, and holding an employee's money longer than that is a separate failure from failing to enroll.
Letting the roster go stale is fourth. Terminated employees who stay marked active generate submission errors and confusion, and the fix is upstream in offboarding rather than in the portal.
And answering investment questions is last. The moment you tell somebody the program is a good deal or a bad one, you have stepped into a role the statute deliberately kept away from you.
Frequently Asked Questions
Who has to register for MyCTSavings?
Private sector employers that employed five or more individuals in Connecticut on October first of the preceding calendar year and paid at least five of them taxable wages of five thousand dollars or more during that year. That definition sits in Conn. Gen. Stat. 31-416. Federal, state and municipal employers are outside it, as is an employer that was not in existence throughout both the current and the preceding calendar year. Covered employers that already sponsor a qualifying retirement plan do not enroll employees, but they still have to say so by certifying the exemption rather than ignoring the notice. Because the count is a single-day snapshot rather than a rolling average, a business can be covered this year and outside the definition next year, so the test is worth rerunning each autumn instead of answering once and filing the conclusion away.
Does the employer have to contribute anything?
No, and more than that: Conn. Gen. Stat. 31-422 says no employer shall be permitted to make a contribution to the program. This is the structural difference between the state auto-IRA and a workplace retirement plan. The employer withholds money from the employee’s own pay and transmits it, and that is the whole of the financial relationship. There is no match, no nonelective contribution, no vesting schedule and no employer money at risk. Program fees are charged to saver accounts rather than to the business. That prohibition is also why the employer is not the plan sponsor, does not choose investments, and does not carry the fiduciary duties that attach to a workplace retirement plan. If you want employer money in the arrangement, the state program is structurally the wrong vehicle and your own plan is the answer.
What is the MyCTSavings registration deadline?
The staged launch deadlines have passed, and the program now runs on an annual cycle. Employers that become newly covered are notified by the state and are expected to register or certify an exemption by August 31 of that year. Because coverage is measured against the October first headcount of the preceding calendar year, a business can cross the line without noticing and receive its first notice the following summer. Treat the notice as the start of a clock rather than as marketing mail, because the enforcement sequence begins from there. Employers that already sponsor a qualifying plan are on the same timetable: the exemption is certified through the program using the access code in the notice, and a covered employer that simply never replies is indistinguishable from one that decided to ignore the mandate.
What are the penalties for not complying?
Public Act 25-30, effective July 1, 2025, replaced the old civil action approach with civil penalties assessed by the Comptroller. The Comptroller sends at least two notices of noncompliance followed by a final notice. For each year an employer remains noncompliant for ninety calendar days or longer after that final notice, it may be assessed up to five hundred dollars, rising to one thousand dollars at the twenty-five employee threshold and one thousand five hundred dollars at one hundred. The penalty repeats annually, so ignoring it compounds rather than resolving. Two separate failures trigger the sequence: not enrolling covered employees, and not transmitting contributions you already withheld from their pay.
How much is deducted from an employee paycheck?
The standard election for savers enrolled since July 2025 is 5 percent of compensation, up from the 3 percent default the program launched with. Under the program description that rate increases automatically by 1 percentage point each January until it reaches 10 percent, unless the saver opts out of the increase. Employees can set any rate they want, including zero, which is how opting out works under Conn. Gen. Stat. 31-422. The employer applies whatever rate the program reports and does not adjust it independently. Savers who do nothing at all simply ride the escalation upward, which is the behavior the federal automatic enrollment rules were designed to produce. Anyone who wants a different number changes it directly with the program.
Is a 401(k) better than the state program?
It depends on whether you want a retirement plan or want to satisfy a mandate. MyCTSavings costs the employer nothing and carries no fiduciary role, but it also gives you no employer contribution to point at when recruiting, and contribution limits for an IRA are far below those of a 401(k). A 401(k) costs real money and real administration, and it lets owners and senior staff defer far more, supports a match, and reads as a genuine benefit. The federal startup credits narrow the cost gap considerably for small employers, covering a share of qualified startup costs for three years plus a separate credit for adding automatic enrollment. The practical question is what you want the money to do: satisfy a statute, or buy something candidates can compare against another offer.
Can we switch from MyCTSavings to our own 401(k) later?
Yes. Sponsoring a qualifying plan exempts you from enrolling employees in the state program, so the usual path is to establish the 401(k) and then certify the exemption through MyCTSavings rather than simply stopping submissions. Existing saver accounts are individual Roth IRAs that belong to the employees, so they continue to exist regardless of what you do. The sequencing matters more than the decision: certify the exemption, then stop remitting, and keep the confirmation. Stopping submissions first is what turns a compliant employer into one receiving notices, because from the state side an unexplained gap in remittances looks exactly like a failure to transmit. Give yourself enough lead time that the plan is genuinely established before the certification goes in.
Do part-time employees count?
Part-time status is not the test. Conn. Gen. Stat. 31-416 defines a covered employee as an individual employed by a qualified employer for at least one hundred twenty days, aged nineteen or older, performing services within the state. Hours are not mentioned, so a long-serving part-time employee is generally covered while a recent full-time hire is not yet. From July 1, 2026 the definition also reaches personal care attendants, with a thirty day service requirement instead of one hundred twenty. Note that the employer-side test is different again: it counts individuals employed in the state on October first regardless of hours, and asks how many of them were paid five thousand dollars or more in taxable wages.