Are QNECs eligible for hardship withdrawals as of 2019?

Qualified Non-Elective Contributions (QNECs) are indeed eligible for hardship withdrawals as of 2019. This eligibility allows employees who have received QNECs to withdraw these funds in case of an immediate and heavy financial need, consistent with the rules governing hardship distributions under the Internal Revenue Code.

The recent changes stemming from the bipartisan budget law passed in 2018 clarified the treatment of QNECs in the context of hardship withdrawals. This clarified that these contributions, which are often made by the employer to help employees meet contribution requirements, can be accessed for hardship reasons alongside participant contributions and other employer contributions.

In considering the context of the question, "only under specific conditions" and "it depends on the employer" would imply limitations or variances in application that don't apply uniformly to QNECs under the specified regulations. While employers can dictate specific withdrawal policies, the general rule has established that QNECs are eligible for hardship withdrawals. Thus, stating that QNECs are eligible as of 2019 aligns with the regulatory framework governing 401(k) plans.