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ARTICLE · 13 OCTOBER 2025

IRS Finalizes Catch-Up Contribution Regulations

Winston Taylor
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401(k) plans may allow employees aged 50 or older to make elective deferrals over the annual limit; these deferrals are known as "catch-up" contributions.

United StatesEmployment and HR
Anne Becker
Anne Becker
Joseph Adams
Joseph Adams
Jaime Schneider
Jaime Schneider
Grant E. Shillington
Grant E. Shillington

401(k) plans may allow employees aged 50 or older to make elective deferrals over the annual limit; these deferrals are known as "catch-up" contributions.

The SECURE 2.0 Act of 2022 added a new requirement that higher-paid participants (i.e., participants who earned at least $145,000 of FICA wages in the prior year (as indexed)) must make catch-up contributions (including any super catch-up contributions for participants aged 60–63) on a Roth basis. Roth contributions are included in a participant's gross income in the year of deferral; however, distributions, including any earnings, are generally tax-free if certain requirements are met. Congress implemented this new Roth catch-up mandate to raise tax revenue to pay for other SECURE 2.0 provisions.

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