Small employer adoption of pooled employer plans is accelerating, and the numbers behind it have moved well past early-adopter territory. The pooled employer plan (PEP) market held an estimated $34 billion in assets at the end of 2025, up from $2.2 billion when the structure launched in 2021, according to industry data tracked from Department of Labor filings. Separate figures from Cerulli Associates show that the number of participating employers grew from roughly 8,600 to more than 51,000 over the same period.
Standard Insurance Company said this week it has surpassed $5 billion in PEP assets under administration. That figure puts a single provider at roughly 15 percent of the total market and signals how quickly concentration is building among established players.
A PEP is a retirement vehicle that lets multiple unrelated employers participate in a single plan while delegating most administrative and fiduciary responsibilities to a pooled plan provider. The structure was created under the SECURE Act of 2019 and became operational in January 2021. The Standard was among the earliest providers to enter the market.
Sponsoring a traditional single-employer retirement plan means carrying fiduciary duties that cover investment selection and monitoring, compliance testing, Form 5500 preparation and signature, plan document management, distribution approvals, and required minimum distribution processing. That list assumes either dedicated HR capacity or outside expertise, and most smaller employers have neither in abundance. Under a PEP, the pooled plan provider takes on the majority of those responsibilities, including 3(16) administrative fiduciary duties, while a registered investment manager handles investment oversight.
The appeal is direct for resource-constrained employers. A single Form 5500 covers all participating employers in the PEP, and plan audits are conducted at the pooled level rather than individually, removing two of the more time-consuming annual obligations that fall on plan sponsors.
In July 2026, The Standard expanded its PEP offering to include an ERISA 403(b) option for nonprofit organizations. The move extended the structure beyond 401(k) plans. Nonprofits tend to carry similar administrative constraints to small private-sector employers but have historically had fewer pooled plan options available to them.
The Standard's $5 billion milestone arrives as PEP adoption continues to broaden across employer segments. Middle-market employers warming to pooled retirement plans has become one of the more prominent conversations in benefits advisory circles over the past year.
Because PEPs remove most day-to-day plan administration from the employer's hands, they also change what an adviser does for that client. Rather than spending time on administrative coordination and compliance deadlines, an adviser can focus on plan design, participation rates, investment lineup quality, and whether the PEP's fee structure holds up against alternatives. That shift in scope can deepen the advisory relationship or thin it, depending on whether the adviser positions as a strategic partner or a plan mechanic.
Research from The Standard, based on its own client base, shows 83 percent of employers with a PEP are satisfied with the experience, with simplified plan management cited as the top benefit. The figure reflects a self-selected group and should be read accordingly, but the direction is consistent with what independent research suggests about fiduciary risk reduction as a primary driver of adoption.
"Our PEP asset growth reflects strong market momentum and increasing demand for our approach," said Steve Chappell, assistant vice president of retirement plan sales at The Standard. "Advisors rely on our fully integrated PEP solution to help clients focus on their priorities while receiving the fiduciary management and administrative support needed to manage their retirement plans."
Not all PEPs, however, are structured identically, and the degree of fiduciary relief they provide varies. Employers, and the advisers guiding them, should evaluate which fiduciary roles the pooled plan provider takes on versus delegates, and how conflicts of interest are managed when the provider also serves as recordkeeper. Whether governance structures give the employer enough transparency without reverting administrative burden back to them is a separate but equally important question. Those considerations apply regardless of which provider is involved.
