Report : Fiduciary Regulatory | December 16, 2025

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

 Important Update

On November 13, the Internal Revenue Service released Notice 2025-67 which increased the Roth catch-up contribution FICA wage limit from $145,000 to $150,000. We know this affects several of our documents and we are in the process of making updates to impacted SECURE 2.0 provisions and materials.

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.
Read our paper

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.