Final Roth Catch-up Regulations: Key Takeaways For Plan Sponsors

The Secure 2.0 Act of 2022 gave us the Roth catch-up mandate, a revenue raiser that has caused great consternation in the retirement plan community as plan sponsors, recordkeepers and payroll providers have grappled with questions regarding how to implement this rule. It quickly became apparent that there were many complex questions and additional guidance was needed. Earlier this year, proposed regulations provided some helpful insights, but left some questions unanswered (described in our prior article). On September 16, 2025, the Department of Treasury and the Internal Revenue Service issued final regulations providing more certainty regarding the applicable rules. Now the ball is in the court of plan sponsors to work with their providers to be ready to comply with the mandate by January 1, 2026. This post summarizes key takeaways in light of the new guidance provided in the final regulations and also outlines next steps for plan sponsors.