On June 26, 2015, in Obergefell v. Hodges, the US Supreme Court ruled that same-sex couples may exercise the right to marry in all states and that a state may not refuse to recognize a lawful same-sex marriage performed in another state. This decision came two years after the Supreme Court's decision in United States v. Windsor, which defined spouse for purposes of federal law to include same-sex spouses lawfully married under state law.

The Same-Sex Marriage Developments for Retirement Plans Toolkit provides many continuously maintained resources to assist retirement plans in complying with the same-sex marriage developments in United States v. Windsor and Obergefell v. Hodges. This Toolkit also provides links to standard clauses and standard documents containing model language.