Embedded Retirement for Contractor Payroll: Plan Sponsorship vs White-Label Subscription

Two integrations that look similar and are not

A payroll platform that pays both W-2 employees and 1099 contractors will eventually field two requests that sound the same: "Can we offer retirement?" For the W-2 side, the answer is an embedded 401(k), and there are mature products for it. For the 1099 side, the answer is structurally different, and treating it as the same product creates legal problems.

This article sets the two side by side. The Gigaverse payroll partner integration is the second kind, and the comparison is meant to show where each belongs rather than to argue one replaces the other.

Option one: plan sponsorship through an embedded recordkeeper

Human Interest's Embedded Retirement (https://humaninterest.com/solutions/embedded-retirement) is the reference model. The payroll platform integrates the recordkeeper's APIs; the platform's employer customers adopt a 401(k) from within the payroll product; the recordkeeper handles plan documents, testing, Form 5500, and investments; payroll deferrals flow automatically.

Who sponsors: each employer customer. The platform is a conduit and technology partner, not a sponsor or fiduciary.

Who participates: the employer's W-2 employees.

What it solves: the state mandate problem. CalSavers reached every California employer with one or more W-2 employees on January 1, 2026 (https://gusto.com/resources/states/retirementmandates), and an employer with a qualified plan is exempt. Gusto and ADP Marketplace both list retirement integrations for this reason; partner requirements vary, so check current partner terms.

What it cannot do: reach a single contractor. If the employer pays eight subcontractors alongside two employees, the eight are outside the plan. Enrolling them would require the employer to treat them as employees.

A pooled employer plan is a variant. Vestwell's PEP for Amazon Delivery Service Partners (https://www.vestwell.com/news/vestwell-launches-retirement-solution-for-amazon-delivery-service-partners), launched June 24, 2025, lets many small employers share one plan. It reduces cost and fiduciary burden. Participation is still limited to W-2 employees of participating employers.

Option two: white-label subscription for individual accounts

The second model does not involve a plan. The contractor is a sole proprietor and can open their own retirement account: a Roth IRA ($7,500 for 2026), or a Solo 401(k) for their own business with a $24,500 employee deferral plus roughly 20 percent of net self-employment earnings as an employer contribution, up to $72,000 ($80,000 at 50 and older). What they lack is the math, the tracking, and the nudge. A subscription app provides those under the platform's brand.

Who sponsors: nobody. The contractor owns an individual account. The platform distributes software.

Who participates: any payee with 1099 income who chooses to.

What it solves: the gap the mandates leave. Every state auto-IRA excludes contractors. MBO Partners counted 72.9 million independents in 2025 (https://www.mbopartners.com/blog/press/2025-state-of-independence-reveals-growing-talent-strategy-for-business), and only 15 to 18 percent of self-employed people use a Solo 401(k) (https://www.solo401k.com/blog/solo401k-adoption-growth-statistics-usa).

What it cannot do: provide employer contributions, payroll deduction, or anything else that implies employment. The contractor funds the account from their own bank account after payout.

Side by side

• •Legal structure. Plan sponsorship: ERISA plan, employer fiduciary, recordkeeper as service provider. White-label: individual account at a broker-dealer, no plan, no fiduciary at the platform.
• •Eligible population. Plan: W-2 employees of employer customers. White-label: 1099 payees.
• •Money movement. Plan: payroll deferrals through the platform. White-label: contractor's own bank transfer after payout; the platform never touches it.
• •Classification effect. Plan: neutral for employees; dangerous if extended to contractors. White-label: reinforces contractor status by treating the payee as a business.
• •Compensation to the platform. Plan: recordkeeper partner terms, subject to ERISA service-provider disclosure. White-label: subscription revenue share or flat per-seat licence, never per enrollee, per deposit, or on assets.
• •Compliance layer. Plan: ERISA and the recordkeeper's compliance. White-label: SEC Marketing Rule promoter disclosures where the platform is compensated, and the broker-dealer's account-opening process.

Why the compensation structures differ

The plan side is governed by ERISA, which permits a range of service-provider compensation as long as it is disclosed and reasonable. The white-label side sits under securities law, where the constraints are tighter. A payment to the platform per contractor who opens or funds an account resembles transaction-based compensation under Exchange Act Section 15(a) and FINRA Rule 2040. A share of advisory fees would violate the rule that an SEC-registered adviser cannot share fees with unregistered parties. Where the platform is compensated for referrals above $1,000 in twelve months, SEC Marketing Rule 206(4)-1 requires a written agreement and a promoter disclosure to the user, and some states require paid solicitors of advisory clients to register as investment adviser representatives.

Gigaverse, which is pursuing SEC RIA registration, therefore pays payroll platforms only a share of revenue on paid app subscriptions or a flat per-seat licence. The user-facing explanation is on the how we make money page.

Running both

Most platforms with mixed payee bases will end up with both integrations, and they do not conflict because they serve different people. The admin experience can present them together: "Offer a 401(k) to your employees" and "Make retirement resources visible to your contractors." The first is a plan the employer sponsors. The second is a resource the contractor uses.

Two details for the contractor side. First, the contribution estimate improves dramatically if the platform passes year-to-date gross payments to the app with the payee's consent; the payee adds expenses, and the engine handles net earnings, self-employment tax, and the limits, including the 2026 mileage split of $0.725 per mile through June and $0.76 from July. Second, starting January 1, 2027, the federal Saver's Match pays up to $1,000 into a non-Roth IRA for lower-income savers, including on Roth contributions, under MAGI phase-outs of $20,500 to $35,500 single, $30,750 to $53,250 head of household, and $41,000 to $71,000 joint. The Saver's Match Roth rule page explains it, and the free tools estimate eligibility.

Where Gigaverse fits

Gigaverse is the white-label subscription option for a payroll platform's 1099 payees. Today the app offers a Roth IRA through a FINRA/SIPC-member broker-dealer; it opens Solo 401(k) and SEP IRA plans through its custodian partner, with applications open now, and provides the contribution math, tracking, and a year-end CPA hand-off alongside them. It is pursuing SEC RIA registration, does not guarantee returns, and pays platforms only through subscription revenue share or flat per-seat licences. It is not a replacement for an embedded 401(k) on the W-2 side. Integration details are on the payroll partner page.