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ARTICLE · 03 JUNE 2025

IRS Proposes Key Changes To Roth Catch-Up Contributions Under SECURE 2.0

Holland & Knight
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The IRS has issued proposed regulations that clarify and implement "super catch-up" contributions changes and mandatory Roth catch-up contributions for "high earners" introduced by the SECURE 2.0 Act of 2022.

United StatesEmployment and HR
Neely Pauley Munnerlyn
Neely Pauley Munnerlyn
Connor Jordan
Connor Jordan
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Highlights

  • The IRS has issued proposed regulations that clarify and implement "super catch-up" contributions changes and mandatory Roth catch-up contributions for "high earners" introduced by the SECURE 2.0 Act of 2022.
  • Although these changes affect various forms of retirement plans, this Holland & Knight alert focuses particularly on 401(k) plans and the new requirement for "high earners" to make Roth catch-up contributions – a provision originally slated to take effect in 2024 but delayed until 2026.

The IRS has issued proposed regulations that clarify and implement catch-up contribution changes introduced by the SECURE 2.0 Act of 2022. Although these changes affect various forms of retirement plans, including 401(k), 403(b) and 457(b) plans, this Holland & Knight alert focuses particularly on 401(k) plans and the new requirement for "high earners" to make Roth catch-up contributions – a provision originally slated to take effect in 2024 but delayed

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