The 401(k) recordkeeping industry has become more concentrated in recent years, with the number of providers decreasing from roughly 400–450 to about 160. Employers have raised concerns that this consolidation could make it harder to find providers who can address their specific needs and may lead to more proprietary offerings. With the recent Gusto Guideline acquisition, mid-sized employers are evaluating how this shift will affect their retirement plans, support, and pricing, especially as state requirements for employer-sponsored retirement plans become more common.

As of late 2025, about 20 states have enacted laws creating state-facilitated retirement savings programs for private-sector workers, many of which require employers that do not sponsor a plan to facilitate enrollment in a state-run option. This growing regulatory pressure is one reason so many employers find themselves navigating provider transitions, making it essential to understand the practical impact of industry changes and new partnerships. For additional context and resources, see our 401(k) resources.

The Short Answer: What Employers Need to Know Now

Industry surveys have found that as many as about 10% of 401(k) plans change providers in a given year, showing how frequently businesses must adapt to a new recordkeeper or platform. The Gusto Guideline acquisition is part of this ongoing trend, and the immediate focus for employers should be to confirm that support contacts and plan features remain in place, that pricing remains transparent, and that teams are prepared for any transition steps.

Change is frequent in the benefits space, but planning ahead can help reduce disruption. State mandates and ongoing consolidation mean employer teams should keep an eye on provider updates and compliance obligations.

For employers looking for more guidance, our 401(k) resources hub is a helpful starting point.

What’s Confirmed vs. What to Verify

Confirmed (Public Statements)

While there are no direct quotes from Gusto or Guideline leaders specifically about service continuity or integration goals, both companies have publicly stated their shared mission to simplify retirement plan access for small and midsize businesses. This type of mission alignment is standard in industry mergers, where the acquiring company typically emphasizes stability and continuity for clients.

Verify (Questions to Ask + Where to Look)

Employers often have questions that go beyond what is addressed in official press statements. Topics like hidden administrative changes, potential blackout periods, and fiduciary roles are frequent concerns. In prior industry transitions, such as the Principal Financial Group’s acquisition of Wells Fargo’s retirement business, phased integrations and dedicated transition teams helped minimize employer disruption.

Employers should review transition communications closely, request detailed checklists, and use resources like the Provider Transition Checklist for HR to stay organized.

Employer Impact Lens 1: Support Continuity

What Support Covers (Plan Admin, Payroll Coordination, Participant Questions)

Support continuity for 401(k) plans includes plan administration, payroll coordination, and participant assistance. During transitions, support teams and online portals often remain unchanged, but features like user-friendly participant and sponsor portals with education resources—long highlighted as market differentiators for Guideline—can make a real difference for both HR and employees.

High-quality support is consistently cited as a key factor in employer satisfaction when changing recordkeepers. Employers should regularly confirm that participant communications, payroll connections, and compliance help remain strong during and after transitions.

For more on this topic, see Guideline Support Changes: How to Plan for Continuity.

Escalation Path and Response Times (What to Document)

Documenting escalation contacts and expected response times is important before and during any transition. This protects your team in the event of delays or issues and can help maintain compliance.

Keeping documentation up to date is a best practice recommended by compliance experts.

Service Continuity Checklist

• Review your current support contacts and escalation paths.

• Confirm participant portal access and key features.

• Audit payroll integrations for any changes.

• Document service-level agreements.

• Review all transition communications.

• Schedule compliance notices and keep them on file.

• Identify backup contacts for critical functions.

• Monitor response times during the transition.

• Track and report any lapses in service.

• Prepare an issue log in case follow-up is needed.

For a downloadable resource, access our Provider Transition Checklist for HR.

Employer Impact Lens 2: Pricing and Fee Clarity

Separate Employer Costs from Participant Costs in Every Proposal

Fee transparency is critical. One report cited in 2024 research found that 401(k) plans with $1 million to under $10 million in assets and 100–499 participants paid a median all-in fee of 1.12% of assets. Employers should always compare this industry benchmark to the specifics of their proposals, and make sure to clearly separate business-paid and participant-paid costs to avoid confusion or compliance risks.

For a deeper dive, review our guide to 401(k) Provider Pricing: True Costs for Employers vs Employees.

Where Changes Often Hide (Setup Fees, Amendments, Add-ons, Advisory)

The most common hidden fees after provider transitions are setup fees, plan amendments, and advisory add-ons, according to industry surveys. Employers should review contracts closely for unexpected charges and consult resources like 401(k) Plan Fees Explained: How Costs Scale as Your Business Grows.

Fee Clarity Questions

• What are the total annual costs for the employer and for participants?

• Are there any one-time setup or amendment fees?

• How are advisory or consulting services billed?

• Will any fees change post-transition?

• Are all costs itemized in the proposal?

• What triggers additional add-on fees?

• Are investment or fund-level fees disclosed?

• How are service level changes communicated?

• Is there a clear escalation process for billing disputes?

• Who is the main contact for fee questions?

For more fee discovery tips, see our A Practical Guide to 401(k) Fee Disclosures for Employers.

Employer Impact Lens 3: Transitions and Deconversion Readiness

What a Transition Typically Requires (Data, Payroll Mapping, Comms)

A successful transition depends on accurate payroll data, careful mapping of integrations, and clear communication between HR, Finance, and participants. Employers should also review compliance documentation and confirm that all deadlines are met. Many providers estimate that deconversion timelines for 401(k) plans often range from about 60 to 90 days, and blackout periods commonly last from several days up to a few weeks, depending on the provider and plan design.

For guidance, read our Guideline Deconversion: Timeline, Blackout Periods, and How to Prepare.

Blackout Basics (What It Means for Employees)

The Department of Labor generally requires plan administrators to give written notice of a blackout period at least 30 days, but not more than 60 days, before the last date participants can exercise affected rights, with limited exceptions. While blackout periods can vary in length, this 30- to 60-day window is the standard federal requirement.

Employers should notify participants early about any restrictions on account changes or transactions.

For more, see our Blackout Period Checklist for 401(k) Migrations.

Timeline Planning Without Dates (Phases + Owners)

• Assign a project owner for the transition.

• Map out project phases: data validation, payroll mapping, participant communication, blackout period.

• Set internal milestones for each phase.

• Schedule required forms and notices.

• Record all handoffs between HR, Finance, and advisors.

• Review progress at each phase before advancing.

Use our Provider Transition Checklist for HR for a step-by-step framework.

Options and Decision Triggers

Stay and Monitor (What Conditions Make This Reasonable)

If service continuity, support responsiveness, and transparent pricing are confirmed, it may make sense for employers to stay with their current provider and monitor participation and engagement benchmarks for signs of post-transition service quality.

For more on this, read Guideline Acquired by Gusto: What Employers Should Expect.

Switch Providers (What Conditions Justify It)

Switching may be justified if there are persistent service disruptions, hidden or rising fees, or major changes to plan administration. Industry surveys suggest that a meaningful minority of 401(k) plans change providers in a given year, so it’s not an unusual decision.

For a practical playbook, see Switching 401(k) Providers: Your No-Drama Playbook.

What to Decide First (Requirements Doc)

Employers should begin by documenting all requirements and transition goals, including fee transparency, support expectations, and integration needs, before making a final decision.

Our How to Build a 401(k) RFP That Gets Real Responses (+ Downloadable Template) covers this process in detail.

Next Steps Checklist

• Review all service agreements for updated contacts and escalation paths.

• Confirm payroll integrations and portal access.

• Document compliance notices and participant communications.

• Assign project owners for each transition phase.

• Track response times and report service gaps.

• Schedule regular progress reviews with your team.

• Maintain an issue log for post-transition follow-up.

Use the Provider Transition Checklist for HR for a structured approach.

CTA for Employers

If you want to future-proof your retirement plan through market changes and consolidations, get started (for employers) with a transparent, compliance-focused 401(k) partner today. The “Get started” page also features planning resources and compliance checklists to support your next steps.

References

• InvestmentNews. (2019). Consolidation of record keepers for 401(k) plans worrisome. https://www.investmentnews.com/retirement-planning/consolidation-of-record-keepers-for-401k-plans-worrisome/75867

• Pew Charitable Trusts. (2024). Small Employers and the Economics of Offering Retirement Savings Plans. https://www.pew.org/en/research-and-analysis/issue-briefs/2024/07/small-employers-economics-of-offering-retirement-savings-plans

• NAPA-Net. (2023). 4 things that seem to scare employers about 401(k)s. https://www.napa-net.org/news/2023/10/4-things-seem-scare-employers-about-401ks/

• Department of Labor. (n.d.). Benefit continuity after organizational restructuring. https://www.dol.gov/agencies/ebsa/about-ebsa/about-us/erisa-advisory-council/2000-benefit-continuity-after-organizational-restructuring

• Guideline Help Center. (2025). Guideline has joined Gusto: FAQs about our recent acquisition. https://help.guideline.com/en/articles/12694322-guideline-has-joined-gusto-faqs-about-our-recent-acquisition