Short answer: Gusto completed its acquisition of Guideline on November 6, 2025. Plans on Gusto payroll became Gusto 401(k) powered by Guideline; plans on other payroll were moved to Accrue 401k, Inc., which Vestwell acquired effective January 30, 2026. If your 401(k) made one of those moves, you can stay where you are, move your payroll, or switch providers. Basic Capital is a 401(k) provider for employers, and most employers that switch are live in 30 to 60 days.

What happened, in order

So a plan that started at Guideline and ran on non-Gusto payroll has had three recordkeepers in about six months: Guideline, then Accrue, then Vestwell.

Which group is your plan in?

You use Gusto payroll

Your plan stayed with Gusto. Gusto’s help center told these customers that their setup “stays exactly the same” and that no pricing changes were planned at the time [7]. Participants now manage the account in the Gusto app; Gusto said the standalone Guideline app would no longer be available by October 2026.

You use another payroll provider and your plan went to Accrue, then Vestwell

Your plan is now recordkept by Vestwell. According to Accrue’s transition FAQ [6]:

• The plan was not terminated. Your plan document, match formula, vesting schedule and eligibility rules carried over unchanged.

• Administrators and employees had to register for new Vestwell logins.

• Plan assets moved to the new platform, with a blackout period during the transfer.

• Some payroll connections had to be set up again.

• Pricing stayed the same as under Guideline and Accrue.

Two earlier changes may still affect you:

• Investment fiduciary. Accrue says some sponsors did not consent to the assignment of their investment management agreement with Guideline Investments, LLC. For those plans, 3(38) investment management stopped and “there is no party actively monitoring or making changes to the plan’s investment options” [1]. Check whether your transition email said this applied to you, and whether anyone has taken on that role since.

• Self-service plans. Accrue says plans whose payroll was not integrated moved to a self-service model, with “several administrative and fiduciary changes” [1]. If that was you, check which tasks moved to your team.

You use another payroll provider and stayed with Gusto 401(k)

Gusto offers employers on other payroll a self-serve portal where you upload payroll and contributions yourself [3, 8]. Gusto’s legal disclosures say its 3(16) plan administration is “only made available to clients who use the integration services available through Gusto’s payroll services” [9]. Without Gusto payroll, the administrative fiduciary role likely sits with you.

Your three options

None of these is urgent by default. A plan that is running correctly can stay put. What matters is knowing who now does each job.

Check these six things now, whichever option you pick

1. Who is your 3(16) plan administrator? Ask for it in writing. It decides who signs Form 5500 and sends required notices.

2. Who is your 3(38) investment fiduciary, if anyone? See the consent issue above. If nobody holds the role, your plan committee (or you) owns fund selection and monitoring.

3. Is your payroll connection live? Compare the last two payroll runs with what posted to employee accounts.

4. Do you have a current fee disclosure? Your new recordkeeper should give the plan’s responsible fiduciary a 408(b)(2) disclosure. File it and compare it with what you paid before.

5. Is the 2025 Form 5500 filed, and by whom? A plan that changed hands during the year can fall between providers. Confirm the filing and keep the confirmation.

6. Do employees have access? Spot-check that a few employees registered on the new platform and can see their balances.

If you decide to switch: a checklist

1. Collect your plan records. Plan document and adoption agreement, most recent Form 5500, last two years of testing results, current fee disclosure, and your payroll provider’s name.

2. Pick a target go-live date. Work back from it. Many employers aim for January 1, but a plan can move mid-year.

3. Compare providers on what changed for you. Payroll integration for your payroll provider, who carries 3(16) and 3(38), the fund menu, Roth and after-tax options, and how pricing works.

4. Review your current agreement. Note the notice period and any termination or deconversion fee.

5. Give notice to your current provider. Your new provider should coordinate the timing.

6. Plan the blackout. Federal rules require the plan administrator to give affected employees written notice of a blackout period at least 30 days, and not more than 60 days, before it starts, with limited exceptions [10]. Use the blackout period checklist for the steps.

7. Carry over year-to-date contributions. In 2026 the employee deferral limit is $24,500 [11]. Your new provider needs each employee’s year-to-date contributions so limits and testing are right after the move.

8. Connect payroll and test it. Confirm the first contribution file posts correctly before the old connection is turned off.

9. Tell employees what changes. New login, blackout dates, and who to call.

10. Reconcile after go-live. Check balances by employee and by source against the old provider’s final statement.

For a week-by-week view, see the 401(k) provider switch timeline.

How Basic Capital handles a move

Basic Capital is a 401(k) provider for employers. Basic Capital Recordkeeping Services LLC is the recordkeeper and acts as 3(16) plan administrator. Basic Capital Advisors LLC, a New York state-registered investment adviser, can serve as the plan’s 3(38) investment fiduciary under a separate agreement; that is optional. Neither is a broker-dealer.

When you move a plan to Basic Capital:

• Your part is two steps. You confirm a few plan details and forward one email we draft to your current recordkeeper.

• We send the transfer notice and manage the blackout.

• We load year-to-date contribution data from your prior provider so annual limits hold after the move.

• We connect your payroll. Basic Capital has 300+ payroll integrations, including Gusto payroll.

• Most employers are live in 30 to 60 days.

After the move, your plan can offer 6,000+ funds plus an optional brokerage window for individual stocks and ETFs, and a mega backdoor Roth (after-tax contributions with in-plan Roth conversions), which the plan turns on after a compliance review. Support averages a 25-minute response time, and 80% of issues are resolved within 24 hours.

To see how this compares with where your plan is now, read how Basic Capital compares with Vestwell or how Basic Capital compares with Gusto 401(k) powered by Guideline. When you’re ready, talk to Basic Capital about a move.

Questions employers ask

Is Accrue 401k still my provider?

No. Accrue’s own help center says plans it administered moved to Vestwell between March 4 and May 6, 2026, and that Vestwell now handles recordkeeping, compliance and participant services [6].

Did my plan design change when it moved to Vestwell?

Accrue says no: match, vesting, eligibility and other plan document terms carried over, and Vestwell administers the plan under your existing plan document [6].

Can I switch to Basic Capital if I run Gusto payroll?

Yes. Basic Capital works with Gusto payroll. You would move the 401(k) to Basic Capital and keep Gusto for payroll.

What does switching cost?

Pricing is tailored to each plan, and we’re consistently competitive. Ask your current provider whether your agreement has a termination or deconversion fee, since that is set by them, not by the new provider.

Do employees have to move their own money?

In a plan-level switch, the plan’s assets move between recordkeepers; employees don’t sell or mail anything themselves. They will need to set up a new login and should expect a short period during the blackout when they can’t change investments or take loans or withdrawals [10].

References

1. Accrue 401k. (2025, November 3). FAQs about your transition from Guideline to Accrue. Accrue Help Center (now offline); archived copy captured May 18, 2026: https://web.archive.org/web/20260518180943/https://help.accrue401k.com/en/articles/12641070-faqs-about-your-transition-from-guideline-to-accrue

2. Gusto. (2025, November 6). The future of retirement benefits starts here: Gusto 401(k) powered by Guideline. https://gusto.com/company-news/gusto-401k (retrieved 2026-11-11; returns 403 to scripts, check in a browser)

3. Guideline. (2025, November 6). It’s official: Guideline has joined Gusto. https://www.guideline.com/education/articles/its-official-guideline-and-gusto (retrieved 2026-11-11)

4. Vestwell. (2025, December 9). Vestwell to acquire Accrue 401k, becoming the new home for nearly 30,000 Guideline retirement plans. https://www.vestwell.com/news/vestwell-to-acquire-accrue-401k (retrieved 2026-11-11)

5. Vestwell. (2026, February 2). Vestwell completes Accrue 401k acquisition. https://www.vestwell.com/news/Vestwell-Completes-Accrue-401k-Acquisition (retrieved 2026-11-11)

6. Accrue 401k. (2026, June 8). FAQ: Your 401(k) plan has moved from Accrue to Vestwell. Accrue Help Center (now offline); archived copy captured June 18, 2026: https://web.archive.org/web/20260618005921/https://help.accrue401k.com/en/articles/13047402-faq-your-401-k-plan-has-moved-from-accrue-to-vestwell

7. Gusto. (n.d.). Gusto and Guideline acquisition FAQs. https://support.gusto.com/article/250827085750957/gusto-and-guideline-acquisition-faqs (retrieved 2026-11-11; 403 to scripts)

8. Guideline. (n.d.). Gusto 401(k) powered by Guideline (home page, “Not on Gusto payroll yet?”). https://www.guideline.com/ (retrieved 2026-11-11)

9. Guideline. (n.d.). Legal disclosures. https://www.guideline.com/legal (retrieved 2026-11-11)

10. U.S. Department of Labor. 29 CFR 2520.101-3, Notice of blackout periods under individual account plans. https://www.ecfr.gov/current/title-29/subtitle-B/chapter-XXV/subchapter-C/part-2520/subpart-A/section-2520.101-3 (retrieved 2026-11-11)

11. Internal Revenue Service. (2025, November 13). 401(k) limit increases to $24,500 for 2026, IRA limit increases to $7,500 (IR-2025-111). https://www.irs.gov/newsroom/401k-limit-increases-to-24500-for-2026-ira-limit-increases-to-7500 (retrieved 2026-11-11)