Nearly half of small employers without a plan weigh pooled plans as deadlines grow

Roughly half of the small employers who lack a standalone retirement plan would consider a pooled arrangement, according to a Transamerica Institute report, and in a growing number of states the fallback for anyone who declines is a compliance deadline. The 48 percent interest figure comes from the institute's May 2026 Employers, Workers, and the New World of Work report, published alongside the firm's 25th anniversary in the pooled plan market, and it applies to employers without a standalone retirement plan rather than to small employers as a group. The number underneath it is harder to argue with: four in 10 private-sector employees at businesses with fewer than 100 workers have no access to a workplace retirement plan at all, according to the Bureau of Labor Statistics' September 2025 Employee Benefits Survey.

A pooled employer plan lets multiple unrelated employers participate in a single plan administered by a pooled plan provider, which assumes most of the administrative and fiduciary work — investment oversight, compliance testing, the Form 5500 filing — while the adopting employer keeps one duty, selecting and monitoring the provider. For an owner with no dedicated HR or finance staff, the appeal is that the work moves off the owner's desk. That retained selection and monitoring obligation is itself a fiduciary decision, so the structure narrows the employer's role without eliminating it.

The market's totals have grown into that pitch. PEP assets reached $34 billion at year-end 2025, held across 330 plans and 10,797 adopting employers, and the adopting-employer count rose 44.8 percent in a single year, according to the 2026 PLANSPONSOR Recordkeeping Survey. The structure launched in 2021 under the SECURE Act with approximately $2 billion in assets, which puts the current total at roughly 17 times that early figure.

Dividing those totals describes the customer better than the headline asset number does. Across 330 plans, the average PEP holds about $103 million; across 10,797 employers, the average adopting employer accounts for roughly $3.1 million, or about 33 employers to a plan. These are small balances gathered into one administrative pool, and they point to fiduciary relief rather than investment scale as the thing an employer is buying. An owner with a few million dollars in plan assets is not shopping for institutional pricing so much as for someone else to run the compliance calendar.

The survey measures what employers say they would consider. The distance between stated openness and a signed plan document, which is where advisory work actually happens, is not closed by a survey response. Interest has to be converted, and the conversion is rarely a brochure.

As of 2026, 17 or more states have enacted legislation requiring employers above a minimum size either to sponsor a qualified retirement plan or to enroll workers automatically in a state-run auto-individual retirement account program. For advisors with small and midsize business clients in those states, a pooled employer plan is the private-market alternative, offering employer matching, plan design flexibility, and higher contribution limits than state IRA programs provide.

That changes the shape of the conversation. An employer who could defer the retirement plan decision indefinitely now faces an external trigger with a cost attached to doing nothing, and the advisor who raises the subject first, with a specific vehicle in hand, is positioned differently from the one who waits to be asked. The population the state mandates target is the population telling Transamerica it is open to pooling, a coincidence advisors can put to work.

The design of the state programs supplies the argument for the private one. Auto-IRA arrangements carry no employer match and no plan design flexibility for the owner, and their contribution limits sit below what a qualified plan allows, which is why the private vehicle is the one an advisor can argue for once a client has decided to comply.

The opening is narrower than the 48 percent suggests. The employers likeliest to move are those in a mandate state, above the minimum size, and without a plan, and an aggregate interest figure does not identify how many sit in that overlap. Everyone else can presumably keep deferring. The mandate gives an advisor a reason to call a specific client about a specific date, rather than making a general case about retirement readiness.

Transamerica's 25 years in the pooled plan market reach back well before the PEP structure launched in 2021, which suggests pooling arrangements predate the statutory label attached to them. The number to watch is the adopting-employer count. At 10,797 it measures adoption directly, while $34 billion cannot show whether the market is still adding sponsors or whether the sponsors already in it have accumulated more. Whether the count keeps rising at anything like 44.8 percent a year depends on the 48 percent of employers without a plan who told Transamerica they were open to the idea, and on the deadlines already on the books in those states.