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ARTICLE · 17 NOVEMBER 2025

SECURE Act 2.0: IRS Issues Final Regulations On Catch-Up Contributions

Gould & Ratner LLP
Gould & Ratner LLP
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The SECURE 2.0 Act of 2022 ("SECURE Act 2.0") makes many changes impacting retirement plans. Among the most significant are changes affecting "catch-up" contributions.

United StatesEmployment and HR
Hrishikesh Shah
Hrishikesh Shah

The SECURE 2.0 Act of 2022 ("SECURE Act 2.0") makes many changes impacting retirement plans. Among the most significant are changes affecting "catch-up" contributions. The IRS recently finalized regulations relating to these changes. In a nutshell, SECURE Act 2.0, together with the final regulations, provide:

  • Roth treatment for higher earners: Catch-up contributions made by employees who earned $145,000 or more in FICA wages (measured as of the prior year and indexed annually) are required to be made on a Roth basis. This provision applies for plan years beginning on or after January 1, 2026.
  • "Super" catch-up contributions: Plans can permit a higher catch-up contribution limit for employees who attain age 60, 61, 62, or 63 during the plan year. For 2025, this limit is $11,250 (the regular catch-up limit for 2025 is $7,500). This provision took effect for plan years beginning on or after January 1, 2025.

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