Final Regulations on Roth Catch-Up Contributions

This technical report provides an overview of the final regulations issued on September 16, 2025, regarding the Roth catch-up mandate established by the Secure 2.0 Act of 2022. The report outlines the requirements for plan sponsors, recordkeepers, and payroll providers as they prepare to comply with the mandate by January 1, 2026. It details the conditions under which Higher Income Participants must make catch-up contributions as Roth contributions and specifies which plans are affected, including 401(k), 403(b), and governmental 457(b) plans. The report explains the implications of the universal availability rule and the criteria for determining Higher Income Participants based on FICA wages. Additionally, it discusses the options available for plan sponsors, including the deemed election approach and the necessary plan amendments that must be adopted by December 31, 2026. The report emphasizes the importance of coordination among payroll providers, recordkeepers, and legal counsel to ensure compliance with the new regulations.