Understanding the IRS Delay of SECURE 2.0 Roth Catch-Up Requirement
October 12, 2023

In the ever-evolving landscape of retirement planning and tax regulations, staying informed about changes that may impact your financial future is crucial.  One such recent development is the IRS's delay of the SECURE 2.0 Roth Catch-Up Requirement.  This delay comes as a response to concerns raised by various industry groups and stakeholders about the practical challenges in implementing this provision.  In this article, we aim to provide an objective overview of what this delay entails and its potential implications for retirement planning.


SECURE 2.0 Roth Catch-Up Rule

The SECURE 2.0 Act of 2022 introduced a significant change regarding catch-up contributions for high-wage earners.  Starting from January 1, 2024, catch-up contributions for individuals aged 50 and above were to be made exclusively on a Roth (after-tax) basis.  This change was designed to generate additional tax revenue and encourage retirement savings among high-income individuals.  High-wage earners, in this context, are defined as those whose wages, calculated similarly to FICA/social security taxes, exceeded $145,000 in the preceding calendar year.


Administrative Transition Period

Recognizing the complexity and potential administrative challenges this change presented for plan sponsors, the IRS and Treasury have issued transitional guidance (Notice 2023-62).  This guidance effectively postpones the implementation of the SECURE 2.0 Roth Catch-Up Rule by two years.


During this two-year "administrative transition period," which extends until the first taxable year beginning after December 31, 2025, catch-up contributions may still be made on a pre-tax basis for participants whose wages exceed the $145,000 threshold.  Furthermore, plans that do not currently permit Roth contributions can continue to allow catch-up contributions to be made solely on a pre-tax basis.


Drafting Errors

There were concerns raised about certain provisions of SECURE 2.0 and their potential impact on catch-up contributions.  Some worried that these provisions could be misinterpreted to imply that catch-up contributions would no longer be allowed from 2024 onward or might affect the tax treatment and limitations of these contributions.


The IRS has clarified that catch-up contributions will remain available on both a Roth and non-Roth basis.  The tax treatment for these contributions will also remain unchanged, ensuring consistency with the rules that were in place before the passage of SECURE 2.0.  Additionally, the aggregate limitations applicable when an employee participates in multiple plans maintained by unrelated employers remain unaffected.


Pending Guidance

While the IRS has provided initial guidance, further clarification is expected on several key aspects of the SECURE 2.0 Roth Catch-Up Rule:


Applicability to Self-Employed Individuals and Governmental Employees: The rule is based on wages subject to FICA/social security taxes.  It remains uncertain whether self-employed individuals and certain governmental employees, who do not receive wages subject to FICA, will be subject to mandatory Roth treatment of catch-up contributions.


Treatment of Pre-Tax Catch-Up Contributions: The Act allows for pre-tax catch-up contributions in specific cases.  Further regulations are expected to address how plan sponsors should treat an employee's election to make pre-tax catch-up contributions if they exceed the income threshold requiring Roth catch-up contributions.


The delay in implementing the SECURE 2.0 Roth Catch-Up Requirement provides relief for plan sponsors and participants, allowing for a smoother transition period. While the IRS has clarified some aspects of this rule, additional guidance is still forthcoming, addressing critical questions about its application.


It is essential for individuals and plan sponsors to stay informed and consult tax professionals or financial advisors to ensure they are complying with the evolving regulations and making informed decisions regarding retirement planning and contributions.  As the landscape of retirement planning continues to evolve, staying educated and proactive remains the key to achieving financial security in retirement.

Retirebetter is dedicated to helping individuals navigate the complex world of retirement planning.  We understand that staying informed about regulatory changes like the SECURE 2.0 Act is just one part of the equation.  

Our mission is to empower you with the knowledge and tools needed to make informed decisions about your retirement accounts, including Roth and 401(k) options.  If you have questions or need assistance with your retirement planning, don't hesitate to reach out to us.  We're here to guide you on your journey towards a more secure and prosperous retirement.