While it’s likely obvious to retirement plan sponsors who’ve been paying attention, one-size-fits-all participant communication strategies aren’t effective. And the challenge is becoming more complex. As workplaces span four (or sometimes five) generations, from Gen Z digital natives to Boomers who prefer print statements, plan sponsors face a tricky balancing act: how to engage different age groups without running afoul of ERISA’s equal treatment requirements.
Recent insights from Chris Carosa, CTFA, writing in Fiduciary News, tackle this growing dilemma head-on. The Department of Labor has acknowledged that retirement plan notices should be available “using a variety of media to address participant communication preferences.” This isn’t just a suggestion—it’s becoming a necessity as workforce research consistently shows that generational preferences reflect fundamental differences in how people process and consume information.
Gen Z workers, who have never known a world without smartphones, expect digital-first communication. They want interactive dashboards, mobile alerts, and video content. Millennials respond best to messaging that connects their 401(k) to life-stage goals like buying a home or paying down student loans. Meanwhile, Boomers prefer clarity and detail delivered through familiar channels like print statements and concise emails. (Notably absent from Mr. Carosa’s breakdown: Gen X, who straddle both eras of analog and digital communications.)
These are more than preferences; they reflect deep behavioral differences. Younger workers typically hold higher equity allocations than Boomers, and retirement confidence varies dramatically across age groups. For plan sponsors, this creates a high-stakes balancing act, according to Mr. Carosa.
“’The generational divide in participant communications introduces subtle compliance risks,’” said Chad D. Cummings, Chief Executive Officer at Cummings & Cummings Law, who was quoted in the Fiduciary News article. “’While personalized dashboards and disclosures can improve engagement, tailoring content too aggressively may raise claims of unequal treatment.’”
The solution lies in what experts call a “baseline-plus-options” approach. Plan sponsors must ensure core plan information remains identical for all participants, regardless of age. But they can layer on optional enhancements, such as video explainers, interactive calculators, and mobile alerts, that participants can choose based on their preferences.
J.M. “Jack” Towarnicky of Koehler Fitzgerald, also quoted in Mr. Carosa’s article, takes this thinking even further. He suggests dropping the word “retirement” from marketing materials entirely. “’Given the diversity of the participant population, from 18-year-old workers who just made their first 401k contribution to 80+ year old millionaire Baby Boomer retirees in payout status,’” he noted, plan sponsors should reposition the 401k as a “Lifetime Financial Instrument” with communications that work at every life stage.
For Boomers specifically, the key is maintaining access to traditional formats without giving them preferential treatment over digital options. “’The solution is to offer multiple formats to all participants that deliver the same underlying information, so no group has an informational advantage,’” Richard Bavetz, investment advisor at Carington Financial, explained in the article..
The compliance guardrail here is ERISA’s “average participant” standard—an objective measure that requires communications to be understandable across the board, not tailored to each generational subgroup. As attorney Marcia Wagner of The Wagner Law Group explained in the article, this standard gives fiduciaries “ample discretion” in how they implement generational awareness while maintaining equal access to information.
The bottom line for plan sponsors: Start with parity, then add personalization as optional enhancements. This approach lets you meet diverse communication preferences while staying compliant with ERISA requirements. In today’s multigenerational workplace, the sponsors who master this balance will be rewarded with better engagement, improved retirement outcomes, and stronger participant trust across all age groups.
