Breaking News: IRS Releases Final Roth Catch-Up Regulations

September 22, 2025

These final regulations apply to retirement plans that permit participants who have attained age 50 to make additional elective deferrals that are catch-up contributions.

More specifically, Section 603 of SECURE 2.0 requires participants with prior year FICA wages of more than $145,000 (indexed) to make their catch-up contributions on a Roth basis [UPDATE: IRS Notice 2025-67 released on 11/13/2025 retroactively changed the threshold from $145,000 to $150,000 -- as such, employees with $150,000 in FICA wages in 2025 will be a "Highly Paid Individual" for 2026 requiring their 2026 catch-up contributions to be made on a Roth basis]. The provision was intended to be a revenue raiser for the legislation by reducing the income deducted through contributions to a pre-tax account. Under prior law, catch-up contributions to a qualified retirement plan could be made on a pre-tax or Roth basis (if permitted by the plan sponsor).

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