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ARTICLE · 30 AUGUST 2023

Catch-Up Contributions Under Secure 2.0: Effective Date Relief

Winston Taylor
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On August 25, 2023, the IRS issued Notice 2023-62, which effectively delays for two years the requirement that certain catch-up contributions in 401(k), 403(b), or governmental...

United StatesEmployment and HR
David E. Rogers
David E. Rogers
Abby Brothers
Abby Brothers

On August 25, 2023, the IRS issued Notice 2023-62, which effectively delays for two years the requirement that certain catch-up contributions in 401(k), 403(b), or governmental 457(b) plans be made as Roth contributions. This requirement, added to the Internal Revenue Code (the Code) by the SECURE 2.0 Act, was to be effective for taxable years beginning after December 31, 2023. Due to concerns raised by many advocates, including the U.S. Chamber of Commerce, ERIC, and the American Benefits Council, as well as many private ERISA practitioners and retirement plan vendors, it will now be first effective for taxable years that begin after December 31, 2025.

Section 603 of SECURE 2.0 requires that any participant who earns more than $145,000 in FICA wages make catch-up contributions in the following plan year as Roth contributions. Some of the issues raised regarding the implementation of the provision include:

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