IRS Issues Final Regulations on SECURE 2.0 Roth Catch‑Up Contribution Rules

On September 15, 2025, the Department of Treasury and the Internal Revenue Service (collectively, the IRS) issued long-awaited final regulations implementing the statutory changes made by the SECURE 2.0 Act of 2022, including the requirement that catch-up contributions made by certain catch-up eligible participants must be designated Roth contributions. The Roth catch-up mandate requires that any catch-up eligible participant whose wages in the prior calendar year exceed $145,000 (indexed) must make any age-50 or age 60 to 63 catch-up contributions on a Roth basis.

Key takeaways for governmental plans from the final Roth Catch-Up regulations are as follows:

• No delay in the January 2026 effective date of the Roth mandate for most plans. Unless the plan is a collectively bargained multiemployer plan, the Roth mandate will go into effect Jan. 1, 2026.
• Plans can be operated under a good-faith interpretation of the Roth mandate in 2026. Governmental plans must apply the final regulations as of the first taxable year beginning after the close of the first regular legislative session of the legislative body with the authority to amend the plan that begins after Dec. 31, 2025.  Until then, governmental plans must be operated under a reasonable, good faith interpretation of the statutory provisions, if they do not follow the final regulations.
• The Roth mandate excludes Special 403(b) and 457(b) Catch-Up Rules.  The Roth mandate does not apply to the special catch-up contribution rules applicable to 403(b) and 457(b) plans.

For more in-depth information regarding SECURE 2.0, please visit MissionSquare’s dedicated SECURE 2.0 website, and look for an invitation to an upcoming webinar covering the final Roth Catch-Up regulations.