Mandatory Roth Catch-Up Provision Delayed until 2026

The IRS granted an administrative transition period via Notice 2023-62 that extends the new requirement per the SECURE Act 2.0 until 2026. The SECURE 2.0 Act requires that any catch-up contributions made by higher‑income participants in 401(k) and similar retirement plans must be designated as after-tax Roth contributions.

The SECURE Act 2.0 which was signed into law on December 29, 2022 included a provision that starting in 2024, catch-up contributions to an employee who participates in a 401(k), 403(b) or governmental 457(b) plan and whose prior-year Social Security wages exceeded $145,000 would be required to be made on an after tax basis via the Roth contribution. The employee would no longer be able to make a catch-up contribution on a pre-tax basis.

The IRS also clarified that plan participants who are age 50 and over can continue to make catch up contributions after 2023, regardless of income.