Employee Benefits Law Blog

On September 16, 2025, the Internal Revenue Service released final rules implementing SECURE 2.0 changes to catch-up contributions under certain retirement plans, including 401(k) and 403(b) plans. Employers should be aware of two key changes.

1. Mandatory Roth Catch Up Contributions for High Earners

Employees whose FICA wages from the plan sponsor exceed the applicable indexed threshold during the prior calendar year ($150,000 for 2026) may only make catch-up contributions on a Roth basis. This is an employer level determination based solely on wages paid by the employer sponsoring the plan, not on an employee’s total compensation from multiple employers.

For employers, this change requires close coordination between payroll systems and plan administration to ensure that catch up contributions for affected employees are properly classified as Roth contributions.

Employers that currently allow catch up contributions should confirm whether their plans and payroll systems are able to support Roth catch up contributions for high earners. If a plan does not permit Roth contributions, the plan sponsor may need to consider whether to implement Roth contributions or discontinue allowing catch up contributions for affected employees.

2. Optional Enhanced Catch-Up Contributions for Participants Aged 60-63

SECURE 2.0 permits (but does not require) an employer to add an enhanced catch-up contribution limit for eligible participants who attain the age of 60, 61, 62, or 63 during the plan year. If the plan is amended to allow this feature, then a participant would be allowed to contribute a higher catch-up amount in lieu of the regular catch-up limit for that year.

For example, the regular catch-up limit in 2026 is $8,000, but for those eligible for the Super Catch-Up it is $11,250. This is a helpful boost for those nearing retirement who want to save more in a short amount of time.

3. Plan Amendment Deadline

Employers should also be mindful of the plan amendment deadline for these changes. For most private sector plans, amendments reflecting the SECURE 2.0 catch up contribution rules generally must be adopted by December 31, 2026. Governmental plans have a later amendment deadline under the extended remedial amendment periods that apply to those plans.

Need Help?

Our Employee Benefits Practice Group regularly assists employers with SECURE 2.0 compliance, plan amendments, and operational coordination. Please contact us if you would like help evaluating how these final rules affect your retirement plan.