S. 2365 (119th)Bill Overview

Small Nonprofit Retirement Security Act of 2025

Taxation|Taxation
Cosponsors
Support
Lean Republican
Introduced
Jul 21, 2025
Discussions
Bill Text
Current stageCommittee

Read twice and referred to the Committee on Finance.

Introduced
Committee
Floor
President
Law
Congressional Activities
01 · The brief
Plain-English summaryWhat this bill actually does

The bill amends the Internal Revenue Code to allow tax-exempt 'eligible small employers' (entities described in section 501(c) and exempt under section 501(a)) to access two existing small-employer retirement incentives: the credit for pension plan start-up costs (section 45E) and the retirement auto-enrollment credit (section 45T). For tax-exempt employers the credits are treated as refundable payroll-tax credits against the employer-side Social Security tax (section 3111(a)), limited to the amount of payroll tax the employer paid in the applicable calendar year.

Why people may split

Scope of eligibility: whether the bill should apply broadly to all section 501(c) entities or be limited to charitable nonprofits (e.g., 501(c)(3)).

Watch point

Relative to its intended legislative type, this bill is a clear, targeted substantive tax-law amendment that extends existing small-employer retirement credits to tax-exempt employers by converting those credits into a payroll-tax credit mechanism and providing an offsetting appropriation to Social Security trust funds.

The bill amends the Internal Revenue Code to allow tax-exempt 'eligible small employers' (entities described in section 501(c) and exempt under section 501(a)) to access two existing small-employer retirement incentives: the credit for pension plan start-up costs (section 45E) and the retirement auto-enrollment credit (section 45T).

For tax-exempt employers the credits are treated as refundable payroll-tax credits against the employer-side Social Security tax (section 3111(a)), limited to the amount of payroll tax the employer paid in the applicable calendar year.

The bill establishes definitions and a limitation rule, makes the changes effective for taxable years beginning after December 31, 2024, and directs transfers from the general fund to the Social Security Old-Age and Survivors and Disability Insurance Trust Funds to offset the revenue reduction caused by the amendments.

Passage40/100

On content alone the bill is a modest, administratively straightforward expansion of existing credits to a defined class of employers and carries low ideological heat, which historically improves chances. However, it creates a direct fiscal cost (though the bill prescribes transfers to Social Security trust funds), so passage depends on committee scheduling, CBO/score treatment, and whether Congress prioritizes standalone technical tax fixes versus packaging into broader legislation. Those procedural and budgetary frictions reduce the estimate from 'likely' to 'plausible but not certain.'

CredibilityPartially aligned

Relative to its intended legislative type, this bill is a clear, targeted substantive tax-law amendment that extends existing small-employer retirement credits to tax-exempt employers by converting those credits into a payroll-tax credit mechanism and providing an offsetting appropriation to Social Security trust funds.

Contention55/100

Scope of eligibility: whether the bill should apply broadly to all section 501(c) entities or be limited to charitable nonprofits (e.g., 501(c)(3)).

02 · What it does

Who stands to gain, and who may push back.

Likely benefits vs burdens50% / 50%
Workers · EmployersFederal agencies · Employers

These are examples from the analysis, not a ranked list of the most-affected groups.

Likely helped
  • WorkersReduces the net cost of starting a retirement plan and adding auto‑enrollment for small nonprofit employers, which supp…
  • EmployersExpands access to credits for organizations that previously could not use nonrefundable income tax credits (tax‑exempt…
  • Potential benefitMay increase demand for retirement plan administration and consulting services (plan recordkeepers, payroll vendors, fi…
Likely burdened
  • Federal agenciesRequires transfers from the general fund to reimburse Social Security trust funds for lost receipts, increasing federal…
  • EmployersImposes additional administrative and compliance burdens on small tax‑exempt employers and payroll processors to calcul…
  • EmployersThe credit is limited to the employer’s payroll tax liability in the year, so small nonprofits with low payroll tax pay…
03 · Why people split

Why the argument around this bill splits.

Scope of eligibility: whether the bill should apply broadly to all section 501(c) entities or be limited to charitable nonprofits (e.g., 501(c)(3)).
Progressive85%

A mainstream liberal/left-leaning observer would likely view this bill positively because it extends retirement plan incentives to nonprofit employers, which often employ lower-wage and mission-driven workers who lack access to employer-sponsored retirement plans.

They would see it as a modest federal intervention to expand retirement coverage and reduce inequality in retirement preparedness among nonprofit-sector employees.

They may note the bill's inclusion of transfers to Social Security trust funds as a responsible fiscal measure, but they might want broader eligibility or stronger outreach to low-income workers.

Leans supportive
Centrist70%

A moderate/centrist observer would likely view the bill as a targeted, incremental policy to increase retirement plan coverage among small nonprofit employers while avoiding permanent reductions to Social Security trust funds by directing general-fund transfers.

They would appreciate the provision that converts the credits into payroll-tax credits so tax-exempt employers that cannot use income-tax credits can still benefit, but would want clear cost estimates, administrative guidance, and guardrails against unintended beneficiaries.

Overall they would see it as a reasonable, limited intervention that could be improved by clarifications and cost-offset transparency.

Leans supportive
Conservative30%

A mainstream conservative observer would likely be skeptical of the bill because it expands a federal tax subsidy to tax-exempt organizations, increases the scope of tax expenditures, and relies on general-fund transfers to replenish Social Security trust funds.

They might question why nonprofits should receive this federal subsidy instead of relying on private solutions or state-level initiatives, and would be concerned about expanding benefits to all organizations described under section 501(c) rather than narrowly to charities.

They would also view the provision as adding cost and potential complexity to payroll-tax administration and might prefer offsets or stricter limits (e.g., sunset, narrower eligibility).

Likely resistant
04 · Can it pass?

The path through Congress.

Introduced

Reached or meaningfully advanced

Committee

Reached or meaningfully advanced

Floor

Still ahead

President

Still ahead

Law

Still ahead

Passage likelihood40/100

On content alone the bill is a modest, administratively straightforward expansion of existing credits to a defined class of employers and carries low ideological heat, which historically improves chances. However, it creates a direct fiscal cost (though the bill prescribes transfers to Social Security trust funds), so passage depends on committee scheduling, CBO/score treatment, and whether Congress prioritizes standalone technical tax fixes versus packaging into broader legislation. Those procedural and budgetary frictions reduce the estimate from 'likely' to 'plausible but not certain.'

Scope and complexity
24%
Scopenarrow
24%
Complexitylow
Why this could stall
  • How the Congressional Budget Office and the relevant committees score the cost and how that score affects budget points of order or the need for offsets.
  • Whether appropriations/transfers language included will be treated as sufficient offset by procedural gatekeepers and budget hawks.
05 · Recent votes

Recent votes on the bill.

No vote history yet

The bill has not accumulated any surfaced votes yet.

06 · Go deeper

Go deeper than the headline read.

Included on this page

Scope of eligibility: whether the bill should apply broadly to all section 501(c) entities or be limited to charitable nonprofits (e.g., 50…

On content alone the bill is a modest, administratively straightforward expansion of existing credits to a defined class of employers and c…

Unlocked analysis

Relative to its intended legislative type, this bill is a clear, targeted substantive tax-law amendment that extends existing small-employer retirement credits to tax-exempt employers by converting those credits into a…

Go beyond the headline summary with full stakeholder mapping, legislative design analysis, passage barriers, and lens-by-lens tradeoff breakdowns.

Perspective breakdownsPassage barriersLegislative design reviewStakeholder impact map
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