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ARTICLE · 23 SEPTEMBER 2025

Final IRS Regulations Address Catch-Up Contributions Under SECURE 2.0

Reinhart, Boerner, Van Deuren SC
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On September 16, 2025, the Internal Revenue Service (IRS) published final regulations regarding changes to catch-up contributions under the SECURE 2.0 Act of 2022 (SECURE 2.0).

United StatesEmployment and HR
Teresa Rose Kulick
Teresa Rose Kulick
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On September 16, 2025, the Internal Revenue Service (IRS) publishedfinal regulationsregarding changes to catch-up contributions under the SECURE 2.0 Act of 2022 (SECURE 2.0). These final regulations generally track the proposed regulations issued in January 2025, but include additional changes as outlined below.

The regulations specifically address implementation of SECURE 2.0's "super catch-up" contribution limits and the requirement that catch-up contributions for certain higher-income participants be designated as Roth contributions.

The final regulations generally apply to contributions made in taxable years beginning after December 31, 2026. However, the applicable date for plans maintained pursuant to a collective bargaining agreement is the later of (i) December 31, 2026, or (ii) the taxable year beginning after the date on which the last collective bargaining agreement in effect on December 31, 2025, terminates. Similarly, governmental plans have until the

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