IRS proposed regulation
Background
On January 13, 2025, the IRS issued a proposed regulation addressing the SECURE 2.0 provisions that pertain to catch-up contributions. This regulation covers, among others, the required Roth catch-up contribution provision, which requires certain catch-up contributions be made in the form of Roth contributions for individuals who exceed a FICA wage threshold.
You can read the full IRS proposed regulation here.
Now that 2025 is underway, plan sponsors should review their plan documents to assess areas that require updates to ensure compliance now and in the years to come. At the end of 2023, IRS Notice 2024-2 extended the deadline for plan amendments relating to the CARES Act, the SECURE Act, and SECURE 2.0. Therefore, no mandatory amendments are due by the end of 2025. However, plan sponsors should decide if making certain amendments now (for example, changes from the CARES Act of 2020) would make sense for their individual plans when it comes to operations and changes already implemented. While many SECURE 2.0 provisions have already taken effect, plan sponsors may want to consider waiting to amend their plans to accommodate future provisions and further government guidance.
Vanguard will continue to share the following important deadlines with you throughout 2025 and beyond: