The IRS has issued final regulations implementing the Roth catch-up provision under the SECURE 2.0 Act of 2022. Key points include:

  • Certain catch-up contributions by higher-income participants must be designated as Roth contributions.
  • Regulations provide guidance for plan administrators on implementation, corrections, and deemed Roth elections.
  • Governmental plans and plans under collective bargaining agreements have a later applicability date, with flexibility for early “good faith” implementation.

Read the full release here.

Recording Available

Final Catch-Up Contribution Regulations for Government Plans
Monday, September 22 | 2 pm ET

On September 22, 2025, NAGDCA hosted a special webinar to review the IRS’s final regulations on catch-up contributions under SECURE 2.0. Executive Director Matt Petersen and David Levine (Groom Law Group) discussed key provisions for governmental plans, including:

  • The $145,000 FICA wage threshold and Roth requirement
  • Clarifications on 457(b) special catch-up rules
  • Implementation timelines and transition relief for public plans
  • Correction methods and coordination with payroll providers and recordkeepers
  • Practical next steps for plan sponsors

If you were unable to attend live, or would like to revisit the discussion, the full recording is now available. We’ve also included the slide deck and an additional resource from the SPARK Institute outlining industry best practices for Roth catch-up implementation.

Access the materials here:

We hope these resources help you and your teams navigate the new requirements and prepare for implementation.