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SECURE 2.0 – Roth Catch-Up Transition Period

September 1, 2023

The SECURE 2.0 Act of 2022 includes a provision that requires catch-up eligible participants with Federal Insurance Contributions Act (FICA) wages of more than $145,000 (indexed) in the preceding calendar year to make catch-up contributions as Roth contributions starting in 2024. 

In response to plan sponsor concerns about being able to timely implement this change, the IRS issued Notice 2023-62. The Notice provides a two-year administrative transition period so plan sponsors, payroll providers, and recordkeepers have more time to modify systems and procedures. As a result, catch-up contributions made in 2024 and 2025 will be treated as satisfying SECURE 2.0, even if the contributions are not designated as Roth contributions and a plan does not provide for Roth catch-up contributions. 

The IRS intends to issue additional guidance regarding SECURE 2.0’s Roth catch-up contributions requirement to assist plan sponsors and service providers in implementing the change. 

This blog was drafted by Beth Miller, an attorney in the Spencer Fane Overland Park, Kansas, office. For more information, visit