Report : SECURE Act 2.0 | September 25, 2025

From proposal to policy: IRS finalizes awaited SECURE 2.0 catch-up contribution regulations

On Tuesday, September 16, 2025, the Department of the Treasury and the Internal Revenue Service (IRS) published the long-awaited final regulations impacting key catch-up contribution provisions of the SECURE 2.0 Act. These rules mark a significant shift in retirement plan administration, particularly for higher-income earners ages 50 and older.

Highlights of these key changes include:

  • The requirement that catch-up contributions must be made as Roth for certain individuals, starting in 2026.
  • Detailed guidance for plan sponsors navigating compliance, corrections, and participant elections associated with Roth catch-up.
  • Clarification for increased catch-up contribution limits for individuals ages 60 to 63.

The final regulations reflect public feedback and aim to balance statutory mandates with administrative flexibility, offering a clearer path forward for both plan sponsors and participants.

To learn more about these regulations, please refer to our paper.