Benefits Monthly Minute

The September Monthly Minute digs into the new final regulations that address SECURE 2.0's Roth catch-up contribution rules.

On September 15, 2025, the IRS released final regulations addressing various SECURE 2.0 catch-up contribution provisions. These final regulations focus not only on requirements for higher-income employees to make after-tax Roth catch-up contributions but also provide procedures for plan administrators to follow when implementing the new Roth catch-up rules. In general, the new final regulations include:

• Aggregation Rules: With respect to each catch-up eligible participant who is subject to the Roth catch-up requirement, the term "employer sponsoring the plan" refers to the participant's common law employer contributing to the plan. However:
  • If the common law employer is a member of a controlled group of employers, the plan may provide that the employee's common law employer is aggregated with one or more other employers in the group