Some people are under the impression, and several articles have indicated, that the final Roth catch-up regulations issued on September 14, 2025 extended the deadline for complying with the Roth catch-up rules. This is not true.

Final Regulations. The final regulations are effective for taxable years beginning after December 31, 2026. However, this does not mean that the requirement that the catch-up contributions of high earners must be Roth contributions has been delayed to that date. The statutory effective date for Roth catch-ups under SECURE 2.0 is taxable years beginning after December 31, 2023. However, in August of 2023, the IRS issued Notice 2023-62 which announced a 2-year administrative transition period (until taxable years beginning after December 31, 2025) to facilitate an orderly transition for compliance with the requirement. During the transition period, the catch-up contributions of high earner participants subject to the Roth requirement are treated as satisfying the Roth requirement even if made on a pre-tax basis.

Administrative Transition Period Not Extended. The final regulations specifically state in the Preamble that they do not extend or modify the administrative transition period. Instead, under the Applicability date section, the regulations state, “. . . this section applies to contributions in taxable years beginning after December 31, 2026. For prior taxable years, a reasonable, good faith interpretation standard applies . . .” Also a plan is permitted to apply the rules of the final regulations in any taxable year beginning after December 31, 2023.

Conclusion. Thus, the administrative transition period ends on December 31, 2025. Thereafter, employers must comply with the Roth catch-up requirement on a reasonable, good faith basis. Compliance with the final regulations prior to their effective date would meet the reasonable, good faith standard. However, not complying with the Roth catch-up requirement in 2026 would not be considered reasonable, good faith compliance.

The final regulations contain much more content other than the applicability date. This article is intended to clear up the confusion over when the Roth catch-up requirement applies. Watch for a more detailed article by my colleague Kevin Nolt in the Trucker Huss Benefits Report coming soon.