Banks are Driving a Quiet Rule Change That Could Reshape Paper Financial and Health Communications—And What It Means for Consumers

Submitted: Two Sides North America September 2, 2026

If you work in paper or print, you may have missed this quiet but consequential move in federal regulation for financial and health communications. Two agencies—the Securities and Exchange Commission and the U.S. Department of Labor—each proposed rules that would make electronic delivery the default way millions of Americans receive important financial and health information, rather than something they have to actively choose.

Neither proposal completely bans paper; both reserve the right to request it. But the shift from “default to paper unless you opt in to email” to “default to email unless you opt out” is a meaningful one, and it’s worth understanding exactly what’s being proposed—and where the consumer’s voice fits in the conversation.

That distinction matters more to consumers than either proposal acknowledges. According to our 2025 Trend Tracker, eighty percent of U.S. consumers say they should have the right to choose how they receive important communications—on paper or electronically—especially when dealing with financial and service providers.

What the SEC is Proposing

The SEC’s new Regulation E-Delivery would let issuers, broker-dealers, and investment advisers send prospectuses, shareholder reports, proxy statements, trade confirmations, and other required disclosures electronically without first getting an investor’s affirmative sign-off. The proposal is being driven and supported by large financial institutions at the expense of the consumer. Consumers already read the motive that way: 63% believe the government, banks and other organizations want to persuade them to “go paperless”—and it is not truly paperless, since many still have to print hard copies at home. Today, paper is still the default unless someone elects otherwise; under the proposal, that flips. Chairman Paul Atkins framed it as retiring a “relic” default in favor of a modern one.

The rule includes a two-notice transition process, and paper delivery remains available on request. However, it is done via email which could be ignored, missed or misidentified as spam or fraud.

What the DOL is Proposing

Separately, the Department of Labor’s Employee Benefits Security Administration proposed a new safe harbor that would let the roughly 2.8 million group health plans governed by ERISA deliver required disclosures digitally by default. The department points that these plans currently print and mail up to 11 billion sheets of paper a year with critical health care information.

The 60-day public comment window for both proposals is open and ends September 21, 2026.

Why This Matters Beyond the Headlines

It’s easy to read these as narrow regulatory housekeeping. But taken together, they represent two of the largest touchpoints Americans have with paper-based communication—investment accounts and health benefits—moving toward an opt-out model at the federal level. That’s a meaningful signal about how regulators are thinking about paper’s role going forward, and it’s the kind of shift that tends to ripple into how other industries frame their own “digital by default” decisions.

It’s also worth being clear-eyed about who these defaults affect most. Not every investor or plan participant is reliably online, confident navigating a portal, or comfortable storing sensitive financial and health documents digitally. That unease is widely held: 65% of Americans say they are increasingly worried that personal information held electronically is at risk of being hacked, stolen, lost or damaged.

Older Americans (and by default, their caregivers), rural households, and people with limited broadband access are disproportionately represented among those who still prefer—or need—paper. An opt-out model puts the burden on exactly the people least equipped to notice and act on it in time.

There’s also a gap between opting into digital and actually engaging with it. Writing in The Financial Brand this month, Chris Juetten argues that paperless enrollment has become a popular KPI because it’s simple, but it hides communication failures. A tax document stored on a portal isn’t the same as being able to retrieve it when needed. A fraud alert sent to an email inbox isn’t always trusted, especially when banks have spent years training customers to distrust exactly that kind of message. (Consumers reported a record $15.9 billion lost to fraud in 2025, up 25% year over year, per the FTC.) A customer who opts into digital but stops opening statements is “paperless” on a dashboard and disengaged in reality. As Juetten puts it, “A rising paperless rate may indicate lower material costs while hiding higher service costs and friction.” Paperless enrollment tells you someone agreed to stop receiving paper. It doesn’t tell you they saw the message, trusted it, or acted on it in time.

This Is Not Only a Generational Issue

It would be easy to assume that preference for paper simply fades with age, but the research does not support that. Seventy-six percent of Millennials and 57% of Gen Z say they should have the right to choose paper over electronic delivery. USPS generational research found Millennials more likely than any other generation to say mail feels more secure than digital communication, and that 72% of Gen Z would be disappointed to stop receiving mail. More recent work puts engagement with direct mail at 85% among Gen Z and Millennials, well above Gen X and Boomers. A default that assumes younger investors and plan participants want digital only is designing against what they say they want.

The Sustainability Argument Doesn’t Always Consider All the Data

There’s also a sustainability case that gets overlooked in these announcements. Paper is a renewable and recyclable material, and North America’s printing and writing paper comes largely from sustainably managed, replanted forests. “Going paperless” is often marketed as the automatically greener choice, but the environmental footprint of digital storage, data centers, and device manufacturing is real and rarely part of the conversation when agencies tout the savings from cutting paper use.

Where You Come In

There is a business risk in getting this wrong: nearly 46% of U.S. consumers say they would consider switching providers if forced to go paperless—up from 41% in 2021. Both proposals still have to run their comment periods, and that’s where facts can shape outcomes. Here at TSNA, we’ve spent years building the evidence based on consumer preference for paper, the sustainability of the paper and print supply chain, and the risks of leaving people behind in a digital-only system. Regulators and lawmakers respond to data and to real testimony from constituents, the industries and consumers affected, not just to agency press releases.

If you are a consumer concerned about digital-only access or a business touches financial services, healthcare benefits communication, or print and mail fulfillment for either sector, please share your voice as both rules move through the comment and finalization process.

Add Your Voice. Both comment periods close September 21, 2026

• Click here to submit your comments on S7-2026-25Top of Form Electronic Delivery of Information Under the Federal Securities Laws.
• Click here to submit your comments on the Electronic Disclosure by Group Health Plans Under ERISA.
• You can also submit your comments using a coalition site for the SEC at ProtectPaperChoice.org
• Comments for the DOL can be made here: Take Action Now!

Paper isn’t going away. But mandating the defaults matters—and this is the moment to make sure paper’s value, and the people who rely on it, stay part of the conversation.

Sources

https://www.afandpa.org/news/2026/why-sec-needs-reconsider-regulation-e-delivery

Trend Tracker Survey Results 2025 – Two Sides North America

SEC.gov | SEC Proposes New E-Delivery Approach to Make Information More Readily Accessible and Useful for Investors

Federal Register :: Electronic Disclosure by Group Health Plans Under ERISA

Labor Department proposes rule expanding disclosure e-delivery for employer plans | HR Dive

Paperless Enrollment Doesn’t Equal Digital Adoption – The Financial Brand

USPS_2020_2021_Generational_Research_Report.pdf

2025 State of Direct Mail Consumer Insights Report | Lob

Global Forest Resources Assessment 2020 | Global Forest Resources Assessment | Food and Agriculture Organization of the United Nations

The Staggering Ecological Impacts of Computation and the Cloud | The MIT Press Reader

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