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Private Equity 401(k) Returns Lag Market

Reported by 401kspecialistmag
Jan 29, 2026· 3 min read
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Key Takeaways
  • • Private equity funds significantly underperformed public equities in the 2023–2025 period, with median annualized returns of 11.24% versus the S&P 500's 22.48% and MSCI ACWI's 20.65%, raising questions about their suitability for retail 401(k) investors.
  • • The Department of Labor has proposed a fiduciary rule with process-based safe harbors to expand access to alternative investments—including private equity—in 401(k) plans, stemming from President Trump's August 2025 executive order, with the proposal now in public comment phase as of March 2026.
  • • Industry participants including the Investment Company Institute and DCALTA are actively developing infrastructure, research, and educational frameworks to support private asset inclusion in defined contribution plans, signaling institutional preparation for regulatory approval.
  • • The timing of expanded 401(k) access to private markets coincides with documented underperformance, creating tension between regulatory expansion and investor protection concerns regarding illiquidity, elevated fees, and returns lagging public market benchmarks.
Summary
The private equity industry is moving toward greater integration with 401(k) retirement plans through regulatory channels, even as performance data highlight significant headwinds. A January 29, 2026 performance report from the Private Equity Secondary Partners (PESP) found that private equity funds delivered a median annualized return of 11.24% over the 2023–2025 period—substantially below the S&P 500's 22.48% and the MSCI ACWI's 20.65% returns. This underperformance underscores the central tension in current policy debates: regulators are moving to expand retail access to private markets precisely when these assets are lagging their public counterparts.

The Department of Labor's regulatory push, originating from President Trump's August 2025 executive order, has advanced significantly. Following White House Office of Management and Budget review completion in late March 2026, the DOL released a proposed fiduciary rule establishing process-based safe harbors for plan fiduciaries seeking to offer alternative investments within ERISA standards. According to 401(k) Specialist reporting (March 30, 2026), the rule reinforces existing fiduciary protections while creating a pathway for private market access in defined contribution plans. The proposal entered public comment phase as of March 25, 2026, with stakeholders across plan sponsorship and advisory communities examining implementation mechanics and potential participant impact.

Industry participants are simultaneously preparing infrastructure to support private asset integration. The Investment Company Institute and DCALTA announced a research and education partnership (February 26, 2026) focused on investor-focused analysis and events promoting alternatives in defined contribution plans. Broadridge's Rachel Puleo noted (January 27, 2026) that technology eliminating fragmentation and creating unified operating models will differentiate market leaders. OneDigital has launched private investment access options within 401(k) platforms, signaling commercial readiness.

However, experts and advocates are scrutinizing both the DOL proposal and the underlying performance case. Coverage in 401(k) Specialist (April 2, 2026) highlighted that while the proposed rule has generated optimism, critical questions persist regarding operational feasibility and participant bearing. Concerns center on private equity's structural characteristics: illiquidity, elevated fee structures, and documented returns that have recently converged with and underperformed public market alternatives. For plan sponsors and fiduciaries, the DOL's safe harbor framework provides regulatory clarity, but performance benchmarks suggest that expanding retail 401(k) access to private markets at this juncture carries material risk relative to publicly traded equity exposure.

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401kspecialistmag Private Equity 401(k) Returns Lag Market