How the Saver’s Match Can Work for More Americans

Pew and the Bipartisan Policy Center urge Treasury, IRS to simplify the Saver’s Match for low-to-moderate-income workers

Speeches & Testimony October 5, 2026

On Oct. 5, The Pew Charitable Trusts and the Bipartisan Policy Center submitted a joint comment to the Treasury Department and the Internal Revenue Service in response to Notice 2026-48, which outlines how the federal government intends to issue regulations for the federal Saver’s Match program.

The Saver’s Match, which takes effect in 2027, will provide a federal matching contribution to eligible retirement savers. It has the potential to boost retirement security for millions of Americans with low to moderate incomes. Drawing on more than a decade of Pew research and input from a broad coalition of experts and stakeholders, the comment letter highlights opportunities to make the Saver’s Match program easier to access and more effective.

To accomplish those goals, the letter urges the Treasury and the IRS to make the new Form 8880-A free to file, streamline its calculations, and prepopulate it with data the IRS already receives, rather than asking filers to enter account numbers manually. The letter also encourages the agencies to favor more automated methods of delivering matching contributions, helping eligible savers avoid unnecessary complexity that could prevent them from accessing the benefit.

These decisions matter because even small obstacles can discourage participation among the households the Saver’s Match is designed to help. By focusing on practical design choices that reduce friction and protect families from unintended consequences—such as losing health coverage or other benefits—these recommendations aim to ensure that the Saver’s Match delivers on its promise to help more Americans save for their futures.

Read our full comment below.

Comments

Although Notice 2026-48 focused primarily on how the Saver’s Match would move from Treasury to retirement accounts, we took a holistic approach to our comments, evaluating both the process and how an individual would interact with that process. Claiming and receiving the Saver’s Match needs to be as simple and automated as possible, because complexity and friction (i.e. processes that slow or prevent claiming) can cause even a highly motivated person to abandon a task. Where possible, we strongly recommend testing user processes and form designs, beginning in the first year, to identify where filers struggle or drop off, followed by participant interviews.

Filing for the Saver’s Match

Form 8880-A

Q.E-1 in the Notice indicated that IRS plans to create a Form 8880-A to claim the Saver’s Match. Assuming this form will be similar to Form 8880, IRS should consider the issues of cost, numeracy, and friction that already exist with Form 8880.

Cost to File: Filers who must pay extra to file forms associated with the Saver’s Match are less likely to claim it. Tax preparation software companies often charge extra for forms they consider “specialized” or “deluxe,” including the Form 8880, which serves to discourage low-income filers from using it to file for the Saver’s Credit. The IRS should ensure that Form 8880-A is included in all Free File options and aggressively promote its Free File options along with the Saver’s Match, as many eligible individuals also qualify for free filing. IRS Free File is available to taxpayers with an Adjusted Gross Income (AGI) of $89,000 or less in 2026,¹ which means that approximately 70 percent of tax filers could qualify based on AGI.² In 2024, a report by the Treasury Inspector General for Tax Administration found that participation in IRS Free File averaged only three percent of eligible taxpayers during the processing years 2020 through 2024.³ Promoting Free File and ensuring that Free File users have a seamless experience filing the new Form 8880-A will ensure more eligible individuals can take advantage of the Saver’s Match.

Numeracy. Filling out Form 8880 requires a high level of ability to comprehend and work with numbers. Other tax programs like the Earned Income Tax Credit (EITC) have seen high rates of incorrect claims, most of which experts attribute not to fraud, but rather to innocent mistakes due to complicated filing processes.⁴ In its current version, the 8880 requires calculations and mathematical reasoning in lines 3, 5, 6, 7, 10, 11, and 12. Although each calculation on its own is fairly simple, the sheer quantity of calculations increases the risk of error—and given that each response is reliant upon accurate calculations from previous lines, one small error at any point could lead to an incorrect final filing. Pew recommends that the forthcoming Form 8880-A be rigorously reviewed and streamlined in terms of the mathematical calculations needed to complete the form.

Friction. Filing Form 8880 involves several steps that can be confusing or time-consuming, leading to tax filers not completing the form. Clearer instructions and fewer calculations would make the process smoother. It is likely that Form 8880-A will need to obtain the same information from lines 1 through 10 of the current Form 8880, with “specified early distributions” substituted for the disqualifying distributions on line 4. In addition, the Form 8880-A should include an option to make the applicable election where the credit total is greater than zero but less than $100. Pew recommends that, where possible, tax software and online filing tools should pre-populate the form with information based on data the IRS already receives, such as provider data, the Saver’s Match destination number, and contributions reported on W-2s and Form 5498. This would minimize the need for manual entry, making it easier for individuals to confirm or update details.

Additional information. Based on the process described in the Notice, a taxpayer will need to enter the Saver’s Match destination number they have received either from their provider or a government website.

Anytime a taxpayer is required to enter a number by hand, there is an increased probability for error. If asked to provide a Saver’s Match destination number, they may use Google or ChatGPT to find the number, transpose numbers, or leave the line blank. Instead of asking the individual to provide the destination number, we encourage Treasury and IRS to use existing data flows, such as those reported on Form W-2 and Form 5498, to establish a default destination for the match. The taxpayer could then be asked to confirm the destination, leading to fewer errors.
If establishing a default destination using existing data is not possible, we recommend that all registered plans and provider numbers are contained in a drop-down menu. The menu should be alphabetical by provider name (or the name the taxpayer is most likely to recognize, for instance, listing a state auto-IRA program by its program name) to assist the taxpayer with selecting the correct provider. This will reduce the likelihood of incorrectly entered numbers.

Form 1040 Non-filers

The Notice laid out a path to access the Saver’s Match for individuals who file a full Form 1040, but nothing for non-filers. In 2022, the Tax Policy Center estimated that nearly 30 million people in the U.S. had neither individual income nor payroll taxes. About 90 percent of households making less than $30,000 paid no federal income tax, as well as about half of those making between $30,000 and $60,000.⁵ Given that low-income households generally are the least likely to save for retirement, and that households making less than the standard deduction are not required to file a Form 1040 ($16,100 for individuals/$32,200 for married filing jointly in 2026), this group of non-filers would be disproportionately impacted by their exclusion from this match.⁶

To remedy this, Treasury and IRS should make available a simplified form for claiming the Saver’s Match, allowing people to certify that their income is below the filing threshold. For those not required to file a Form 1040, a streamlined option—like the IRS’s Non-Filer Sign-up Tool—could help.⁷ The IRS could also work with local organizations to help low-income individuals claim the matching funds. Promoting the Saver’s Match along with other tax benefits, like the Earned Income Tax Credit (EITC), could encourage more people to participate.

As another option, IRS could add a checkbox to Form 8880-A whereby individuals would attest that their AGI is below the threshold that requires them to file a Form 1040. There could be a formal attestation at the bottom of the form, to ensure that people only select the box if they truly do not need to file Form 1040, as well as an address that accepts Form 8880-A filings without an accompanying Form 1040.