PEPs Become Key Part of Recordkeepers’ Growth Strategy

More than 50,000 employers in the U.S. have joined a pooled employer plan, creating opportunities for recordkeepers to grow their businesses and differentiate their organizations in the retirement plan marketplace, according to new data from Cerulli.

PEPs first launched 5.5 years ago after being authorized in the Setting Every Community Up for Retirement Enhancement Act of 2019. The PEP market boomed to about $30 billion in assets as of the end of 2025, according to a recent report from the Georgetown Center for Retirement Initiatives. The latest edition of “Cerulli Edge—U.S. Retirement Edition,” which surveyed recordkeepers in 2025, found recordkeepers are picking up the pace to facilitate the growth: 58% of recordkeepers already recordkeep PEPs, with an additional 17% reporting plans to do so in the next 12 months.

Recordkeeper respondents to Cerulli’s study said they believe PEPs will have a positive impact on their business, with 42% calling PEPs a major strategic priority and 29% ranking PEPs as a moderate priority. Separately, 64% of respondents said they expect PEPs to have a positive impact on their business in 2026.

Recordkeepers focused on PEPs reported expecting between 20% and 40% of their sales growth this year to stem from PEPs, the report stated. Respondents also said that in a few years, most of their new business will derive from PEPs.

Respondents to the 2026 PLANSPONSOR Recordkeeping Survey reported that 10,797 employers have adopted PEPs for their 401(k) or 403(b) participants, up from 7,454 last year—a 44.8% increase.

Plans joining PEPs are mixed in tenure, recordkeepers reported to Cerulli. The firm’s 2025 DC Recordkeeper Survey found that recordkeepers say an average of 60% of employers that joined PEPs in 2024 already had an existing retirement plan. The remaining 40% represented employers offering new retirement plans.

Among plan sponsors reporting plans to search for a new recordkeeper in the next year, 28% reported considering a PEP as part of their review process, Cerulli’s newest data showed. Sponsors that are less inclined to make a change, but still conducting a recordkeeper review, also reported including PEPs in the process (16%).

Competition and the Path Ahead

Despite their early success—and perhaps because of it—PEPs have also introduced competitive dynamics and some friction into the marketplace, the report cautioned. Some recordkeepers are losing plan sponsor clients to distribution partners that offer PEPs recordkept by a competitor. Cerulli’s study found that aggregators and consultants are the “early winners” in the emerging PEP marketplace, holding 40% of all PEP assets and five of the top 15 PEP providers.

Since the first PEPs launched in 2021, several recordkeepers have established their own open or off-the-shelf PEPs, which are sold directly to sponsors or available for advisers to use with their clients. Advisory firms, individual adviser practices, national consultants and professional employer organizations, among others, have also established PEPs by partnering with pooled plan providers and recordkeepers to create their own, branded PEPs.

The latter model, known as “white-label” PEPs, leads among the two, holding 78% of all PEP assets as of the end of 2025, according to Cerulli’s report. With many large advisory and consulting firms having already partnered with recordkeepers to launch PEPs, there may be fewer big opportunities for recordkeepers just entering the market, the report warned.

But the adoption of PEPs by employers with larger plans is just starting to take off, meaning recordkeepers’ opportunities have not run dry just yet. According to the Cerulli report, recordkeepers that have had early success with PEPs share several common characteristics:

• a legacy multiple employer plan and group plan business providing the recordkeeping capabilities and service models needed to administer PEPs;
• a willingness and ability to work with multiple PPPs, 3(38) investment management fiduciaries and third-party administrators to create white-label PEPs aligned with the needs of distribution partners; and
• an ability to provider advisers with education, customized branding and user experience, as well as tools and analytics they can use to identify PEP prospects within their existing client base.

Looking ahead, Cerulli expects the PEP market to grow and evolve as more advisers and consultants offer PEPs, recordkeepers develop their capabilities and larger plan sponsors adopt them, the report stated.