More than 50,000 employers have now joined a pooled employer plan, and recordkeepers are racing to capitalize on the growth.
A recent PlanAdviser article highlights findings from the latest Cerulli Edge—U.S. Retirement Edition, which surveyed recordkeepers in 2025. The data shows PEPs have become a major strategic focus: 58% of recordkeepers already record-keep PEPs, with another 17% planning to do so within the next 12 months. Among those surveyed, 42% called PEPs a major strategic priority, 29% ranked them a moderate priority, and 64% said they expect PEPs to have a positive impact on their business in 2026.
Recordkeepers focused on PEPs are expecting the segment to drive 20% to 40% of their sales growth this year. Some said that within a few years, most of their new business will come from PEPs.
According to the 2026 PLANSPONSOR Recordkeeping Survey, 10,797 employers have adopted PEPs for their 401(k) or 403(b) plans—up 44.8% from 7,454 the year before. The PEP market reached roughly $30 billion in assets by the end of 2025, according to the Georgetown Center for Retirement Initiatives.
Plans joining PEPs are a mix of existing and new. Cerulli found that 60% of employers that joined PEPs in 2024 already had a retirement plan in place, while 40% were first-time plan sponsors. Among plan sponsors planning to search for a new recordkeeper in the coming year, 28% said they’re considering a PEP as part of their review.
The competitive picture is shifting too. Aggregators and consultants have emerged as early winners in the PEP market, holding 40% of all PEP assets and five of the top 15 PEP providers. White-label PEPs—where advisory firms or consultants partner with a pooled plan provider and recordkeeper to create their own branded offering—now account for 78% of all PEP assets. With many large advisory and consulting firms already having launched PEPs, Cerulli cautions that there may be fewer big opportunities for recordkeepers just entering the market.
That said, adoption among larger plan sponsors is just beginning. Cerulli found that recordkeepers with early PEP success tend to share a few characteristics: a legacy MEP or group plan business that provides the infrastructure to administer pooled plans; a willingness to work with multiple pooled plan providers, 3(38) fiduciaries, and TPAs to build white-label solutions; and the ability to offer advisers education, customized branding, and tools to identify PEP prospects within their existing client base.
For recordkeepers still on the sidelines, the window to compete may be narrowing—but it hasn’t closed yet.
