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ARTICLE · 09 OCTOBER 2025

SECURE 2.0 Update: Final Roth Catch-Up Regulations, More Decisions To Make

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SECURE 2.0 requires that catch-up contributions made by employees with FICA wages of more than $145,000, indexed and based on prior calendar year wages, be designated as Roth contributions.

United StatesEmployment and HR
Kutak Rock
Kutak Rock

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SECURE 2.0 requires that catch-up contributions made by employees with FICA wages of more than $145,000, indexed and based on prior calendar year wages, be designated as Roth contributions. Final regulations regarding this new mandate were released in September and make clear that employers have several decisions to make in implementing this new requirement. The mandate is still effective January 1, 2026. Amendments to plan documents are not required until December 31, 2026, or December 31, 2029 for governmental plans.

To Deem or Not to Deem

The final regulations provide different approaches for implementing the Roth catch-up mandate. Under the deemed approach, all elections by catch-up-eligible employees subject to the mandate shift to Roth when contributions hit the Code Section 401(a)(30) (i.e., $23,500 in 2025) limit. The regulations permit the shift to occur when all an employee's contributions reach the

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