A newer law in the Commonwealth of Virginia says employers must provide a retirement withholding option for all employees. If you do not have a retirement plan, you must enroll in RetirePath Virginia. Churches are not exempt from this policy.
What is RetirePath Virginia?
RetirePath is a program in the Commonwealth of Virginia aimed at providing a retirement account savings program. It is designed to ensure every employee in Virginia has a retirement savings option. The program was originally passed by the Virginia General Assembly in 2021, with the RetirePath program opening in 2023. The program expanded on July 1, 2026, so every employer with 5 is now required to register for RetirePath or provide an alternative retirement savings plan.
What Businesses Must Participate?
RetirePath Virginia is a mandatory program for all businesses that meet the following criteria:
- Business has 5 or more eligible employees,
- Business has been operating for two or more years, and
- Business does not offer a qualified, employer-sponsored retirement savings plan.
Employees are eligible if they are over 18 years of age and are paid employees, regardless the number of hours worked per week or the pay rate. The only exception provided is for temporary or seasonal employees who work less than 90 days a year, who do not count towards the “5 or more eligible employees.”
Is My Church Excluded from the RetirePath Virginia program?
Unlike other payroll related policies, such as Federal and State Unemployment, churches are not automatically exempt from the program. If your church has been operating for at least two years and has at least 5 eligible employees on payroll, you may be required to sign up for RetirePath.
What may exclude your church from the mandatory registration is a qualified retirement savings plan. In the United Methodist Church, the local church can invite lay staff to enroll in the Personal Investment Plan (PIP) plan through Wespath. This is a 403b plan, which can be set up as a matching or non-matching plan for United Methodist Churches. Other denominations offer similar options, such as the Retirement Savings Plan in the PC(USA), which is managed by the PC(USA) Board of Pensions.
Please note, it is not sufficient that these retirement plans exist. Employees are not automatically qualified to enroll in these denominational plans. Your church must sign up for and offer a retirement plan to be exempt from the RetirePath Virginia program. Your employees must have a way to withhold for retirement as part of their payroll to be exempt from RetirePath.
How Much Does RetirePath Virginia Cost?
If your church signs up to participate in the program, there is no direct cost for your church. You do not have to pay RetirePath for the retirement program services, nor is your church required to contribute to your employees’ retirement programs. Your obligation is to facilitate employee registration and to withhold and submit any retirement funds as specified for enrolled employees.
There are fees for businesses who do not comply with the requirements, which can cost up to $200 per eligible employee per year.
Employers wanting to learn more about the program should visit the RetirePath FAQs for Employers.
What Kind of Retirement Plan does RetirePath Virginia Provide?
The RetirePath Virginia program sets up a Roth IRA account for each participating employee. If an employee is already contributing and maximizing their Roth IRA contributions, they can redirect their RetirePath contributions to a traditional IRA.
Though your church or business may be required to offer RetirePath for your employees, your employees are not required to enroll. Enrollment is optional for employees. It’s also worth highlighting that, while there is no fee for the employer to provide RetirePath as an option, there is a fee for employees who elect to enroll. There is both a standard account fee as well as an asset-based fee assessed on the balance of the account.
Employees wanting to learn more about RetirePath Virginia should visit the RetirePath FAQs for Savers.
What is the Deadline for Registering?
If your church (or business) meets the qualifying criteria and does not offer a retirement savings options, you may be required to register quickly.
- Employers (i.e., churches) with 10-24 employees must register by September 30, 2026
- Employers with 5-9 or 25+ employees must register by October 30, 2026
Is your church eligible for RetirePath? Take the Eligibility Quiz today.
If your church is eligible, you can register online.