Final Secure 2.0 regulations regarding catch up contributions
This morning the IRS in IR-2025-91 announced that the pending Secure 2.0 final regulations regarding catch-up contributions to qualified retirement plans will be published tomorrow, 9/16/2025, in the federal register.
My initial reading of a summary has two key takeaways for me.
A requirement that catch-up contributions that will require such catch-up contributions to be ROTH for certain taxpayers based their on earned income ($145K indexed) of the prior tax year.
The effective date of the new catch-up provision will now be for tax years after 12/31/2026, so starting in 2027 for plans using calendar years.
I am certain there will be matters in final regulations that will be of concern to others. An advanced copy of the 94 pages of final regulations are here.
A more readable early read summary from the National Association of Plan Advisors (NAPA) is what I am currently reading. The NAPA comment "Under SECURE 2.0, the deadline for compliance was initially for tax years beginning after Dec. 31, 2023, but it was postponed to 2026 by the IRS due to its administrative complexity." is a understatement of the tax complexity these regulations require. Ultimately the cost of such tax complexity will be absorbed by the plan participants regardless if they make catch-up contributions or not.
My initial reading of a summary has two key takeaways for me.
A requirement that catch-up contributions that will require such catch-up contributions to be ROTH for certain taxpayers based their on earned income ($145K indexed) of the prior tax year.
The effective date of the new catch-up provision will now be for tax years after 12/31/2026, so starting in 2027 for plans using calendar years.
I am certain there will be matters in final regulations that will be of concern to others. An advanced copy of the 94 pages of final regulations are here.
A more readable early read summary from the National Association of Plan Advisors (NAPA) is what I am currently reading. The NAPA comment "Under SECURE 2.0, the deadline for compliance was initially for tax years beginning after Dec. 31, 2023, but it was postponed to 2026 by the IRS due to its administrative complexity." is a understatement of the tax complexity these regulations require. Ultimately the cost of such tax complexity will be absorbed by the plan participants regardless if they make catch-up contributions or not.
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