IRS Delays SECURE 2.0's Roth Catch-up Mandate until 2026

Summary

Newly released IRS guidance provides a welcome two-year delay of the Roth catch-up mandate, originally scheduled to take effect next year for high-earning employees under the SECURE 2.0 Act of 2022 (Div. T of Pub. L. No. 117-328). Notice 2023-62 also previews more comprehensive guidance IRS expects to issue in the future and confirms that catch-up contributions are still permitted after this year, despite an apparent drafting error in SECURE 2.0. Comments on the notice are due Oct. 24.