SECURE 2.0 Act 2026 Mandatory Provisions: Roth Catch-Up, Plan Amendments, and Practitioner Guide

The SECURE 2.0 Act of 2022 (enacted December 29, 2022, as part of the Consolidated Appropriations Act, 2023) made more than 90 changes to the retirement plan rules of the Internal Revenue Code. Several of those changes became mandatory operational requirements in 2025 and 2026. For enrolled agents, CPAs, and tax attorneys advising plan sponsors and participants, the next six months are the most consequential compliance window since SECURE 2.0 was enacted: the Roth catch-up mandate is now in effect, the December 31, 2026 plan amendment deadline applies to most plans, and good-faith compliance relief under IRS Notice 2024-2 begins to expire on January 1, 2027.

This guide is written for practitioners who advise plan sponsors and participants. It covers: the Roth catch-up contribution mandate and good-faith relief; the December 31, 2026 plan amendment deadline; auto-enrollment requirements for new plans; RMD age changes; enhanced catch-up contributions for participants ages 60-63; student loan matching contributions; and pension-linked emergency savings accounts. All dollar amounts, thresholds, and rates: verify at IRS.gov before use in client engagements. For the broader 2026 planning context under the One Big Beautiful Budget Act, see the Section 199A QBI Deduction OBBBA Practitioner Guide. This guide is informational and does not constitute legal or tax advice.

Section 1: SECURE 2.0 Act Overview

Enactment and scope

The SECURE 2.0 Act of 2022 was enacted on December 29, 2022, as Division T of the Consolidated Appropriations Act, 2023 (Public Law 117-328). It follows the original Setting Every Community Up for Retirement Enhancement Act of 2019 (SECURE Act 1.0) and makes over 90 changes to the rules governing 401(k) plans, 403(b) plans, SIMPLE IRAs, SEP-IRAs, IRAs, and other retirement arrangements. The changes span plan design, contribution limits, required minimum distributions, automatic features, hardship withdrawals, small employer incentives, and plan administration.

Staggered effective dates

SECURE 2.0's effective dates are intentionally staggered. Some provisions were effective immediately in 2023; others phased in through 2024, 2025, and 2026; and some do not become effective until 2027 or later. The staggered structure was intended to give plan sponsors and TPAs time to update systems and procedures. However, the convergence of the Roth catch-up mandate, the auto-enrollment requirement, and the December 31, 2026 plan amendment deadline makes 2026 the highest-stakes compliance year in the SECURE 2.0 rollout. This guide focuses on the 2025-2026 operational requirements and the December 31, 2026 amendment deadline.

Key effective dates: reference table

For the broader 2026 planning environment, including the One Big Beautiful Budget Act's effect on pass-through income and individual tax rates, see the Section 199A QBI Deduction OBBBA Practitioner Guide.

Section 2: The Roth Catch-Up Mandate (Section 603, IRC 414(v)(7))

What the mandate requires

SECURE 2.0 Act Section 603 added IRC 414(v)(7), which requires that for plan years beginning on or after January 1, 2026, catch-up contributions made by participants whose prior-year FICA wages from the plan sponsor exceeded the applicable dollar threshold must be designated as Roth catch-up contributions -- that is, after-tax contributions to a Roth account. The threshold is not a fixed amount; it is adjusted annually for inflation. Practitioners must verify the applicable threshold for each plan year at IRS.gov. Do not use a specific dollar amount unless you have confirmed the current year's inflation-adjusted figure directly from IRS.gov.

Who is affected

The Roth catch-up mandate applies only to participants who: (1) are age 50 or older and otherwise eligible to make catch-up contributions; and (2) received FICA wages from the plan sponsor in excess of the applicable IRS.gov threshold in the preceding calendar year. Participants who earned at or below the threshold are NOT subject to the Roth mandate and may continue to make pre-tax catch-up contributions in the same manner as before SECURE 2.0.

Note: the wage test is based on FICA wages from the plan sponsor (not gross income, total compensation, or wages from other employers). A participant who earned above the threshold from an employer other than the plan sponsor is not subject to the Roth mandate for that plan. For participants who are self-employed (sole proprietors or partners), different rules apply; hedge to IRS.gov and the final regulations for self-employed participant treatment.

Plans without a Roth feature: the critical issue

Good-faith compliance relief: IRS Notice 2024-2 and final regulations

IRS Notice 2024-2 provided administrative transition relief for the Roth catch-up mandate, and the IRS issued final regulations on September 16, 2025. Under the relief, plans that cannot yet implement the Roth catch-up requirement may continue accepting pre-tax catch-up contributions from all participants (including those who would otherwise be subject to the Roth mandate) through January 1, 2027, provided the plan acts in good faith to implement the requirement. The good-faith compliance period runs through the first plan year beginning on or after January 1, 2026 for most calendar-year plans, with additional relief extending to January 1, 2027. Hedge the exact scope and current status of the good-faith relief to IRS Notice 2024-2 and IRS.gov; the final regulations may have modified or clarified the relief described in Notice 2024-2.

The relief does not eliminate the mandate; it defers the enforcement consequence for plans operating in good faith. Plan sponsors who have not yet implemented the Roth catch-up feature must do so before the relief period ends or lose the ability of high-earning participants to make catch-up contributions at all.

Payroll and recordkeeping implications

Implementing the Roth catch-up mandate requires coordination between the plan sponsor, the payroll provider, and the TPA. The plan must be able to: identify which participants' prior-year FICA wages from the sponsor exceeded the applicable threshold; route those participants' catch-up contributions to a Roth account within the plan; issue separate W-2 coding for Roth catch-up contributions; and track the Roth catch-up contributions separately for recordkeeping and 1099-R purposes. Practitioners advising plan sponsors should initiate a payroll and TPA readiness conversation immediately if they have not done so already.

Section 3: The December 31, 2026 Plan Amendment Deadline

Why plan amendments are required

A qualified retirement plan must be maintained pursuant to a written plan document that meets the requirements of the Internal Revenue Code. When Congress changes the retirement plan rules (as SECURE 2.0 did extensively), plans must formally amend their documents to reflect those changes. The IRS generally permits plans to adopt changes operationally first (that is, operate under the new rules before the written document is amended) and then amend the document by a specified deadline. IRS Notice 2024-2 set the plan amendment deadline for most SECURE 2.0 provisions at December 31, 2026.

What the deadline covers

The December 31, 2026 deadline applies to the formal amendment of plan documents to reflect all SECURE 2.0 provisions that the plan adopted operationally from 2023 through the plan year beginning in 2026. This is not limited to the Roth catch-up mandate. It includes every SECURE 2.0 provision the plan chose to implement or was required to implement: auto-enrollment, student loan matching, PLESAs, enhanced catch-up for ages 60-63, RMD age changes, and other applicable provisions. The amendment must reflect the plan's actual practice during the operational compliance period.

Who must act

The plan sponsor (the employer) is responsible for ensuring the plan document is amended by the deadline. In practice, the amendment is typically prepared by the plan's TPA or plan counsel and adopted by the plan sponsor through a board or plan sponsor resolution. Practitioners -- enrolled agents, CPAs, and tax attorneys -- who advise plan sponsors should proactively identify all applicable SECURE 2.0 provisions the plan has adopted operationally and ensure the TPA and counsel have the amendment on their work schedule for completion well before December 31, 2026.

Governmental plans

Governmental plans (including governmental Section 457(b) plans and governmental Section 403(b) plans) have separate effective dates and compliance timelines for some SECURE 2.0 provisions, and may have different plan amendment deadlines. Practitioners advising governmental plan sponsors must verify the applicable deadlines for governmental plans at IRS.gov; do not assume the December 31, 2026 deadline applies uniformly to governmental plans.

Source citations

The December 31, 2026 plan amendment deadline is set out in IRS Notice 2024-2, which also addresses interim operation and good-faith compliance relief for multiple SECURE 2.0 provisions. The IRS issued final regulations on the Roth catch-up mandate on September 16, 2025. Verify all current amendment guidance, including any updates or clarifications issued after the date of this guide, at IRS.gov.

Section 4: Auto-Enrollment Mandate (Section 101)

Which plans are covered

SECURE 2.0 Act Section 101 requires that 401(k) plans and 403(b) plans established after December 29, 2022 (the date of SECURE 2.0's enactment) must include an eligible automatic contribution arrangement (EACA) beginning with the first plan year beginning on or after January 1, 2025. Plans established on or before December 29, 2022 are grandfathered and are not required to add automatic enrollment under this provision, though they may adopt it voluntarily.

Deferral percentages and escalation

The auto-enrollment requirement mandates that the plan enroll eligible employees at an initial deferral percentage of at least 3% (and not more than 10%), with automatic annual escalation of the deferral percentage until the employee reaches at least 10% (and not more than 15%). Both the initial deferral range (at least 3%, not more than 10%) and the maximum escalation ceiling (at least 10%, not more than 15%) are specified in SECURE 2.0 Act Section 101. Verify the current applicable percentages and any IRS guidance on the EACA requirements at IRS.gov and SECURE 2.0 Section 101 before advising clients; the IRS may issue additional guidance on implementation. Employees retain the right to opt out of automatic enrollment or change their deferral percentage.

Exceptions to the auto-enrollment mandate

SECURE 2.0 Act Section 101 includes exceptions for: (1) church plans (as defined in IRC 414(e)); (2) governmental plans (as defined in IRC 414(d)); (3) plans maintained by employers that have been in existence for fewer than 3 years (new businesses); and (4) plans that have had fewer than 11 employees on average during the prior calendar year (small plans). These exceptions may apply differently based on the specific facts. Hedge all exception criteria to IRS.gov and SECURE 2.0 Section 101; do not advise a client that an exception applies without confirming the current exception standards.

Compliance steps for new plans

Practitioners advising plan sponsors of 401(k) or 403(b) plans established after December 29, 2022 should confirm: whether the plan has implemented automatic enrollment for plan years beginning on or after January 1, 2025; whether the EACA uses an initial deferral percentage that satisfies the statutory range; whether the automatic escalation feature is operational; and whether the plan document has been updated to reflect the EACA requirements (or is on track for amendment by December 31, 2026). Failure to implement mandatory auto-enrollment in a covered plan is a plan qualification defect.

Section 5: RMD Age Changes (Sections 107 and 204, IRC 401(a)(9))

The new RMD ages

SECURE 2.0 Act Sections 107 and 204 amended IRC 401(a)(9) to increase the age at which required minimum distributions must begin. Two different RMD ages now apply, depending on when the participant reaches the applicable birth-year threshold:

• Age 73: applies to individuals who reach age 72 after December 31, 2022 and before January 1, 2033. These individuals must begin RMDs at age 73.
• Age 75: applies to individuals who reach age 74 after December 31, 2032. These individuals will not be required to begin RMDs until age 75.

The transitional rules mean that different participants in the same plan may have different RMD ages depending on their birth year. Practitioners and plan administrators must track each participant's birth year to determine the applicable RMD start date. Verify all transitional rules and edge cases at IRS.gov and in the current IRC 401(a)(9) regulations.

Required beginning date

Under IRC 401(a)(9), the required beginning date for RMDs is April 1 of the calendar year following the year in which the participant reaches the applicable RMD age. For non-5% owners who are still employed, the required beginning date may instead be April 1 of the year following the year the participant retires (if later). This "still-working exception" does not apply to IRA owners; IRA RMDs must begin based on age alone.

The RMD age increase has estate planning implications: participants who can defer RMDs longer may allow more tax-deferred growth in retirement accounts, but that also affects inherited IRA and beneficiary RMD planning. For the estate planning intersection with retirement accounts and how RMD deferral interacts with estate tax and portability planning, see the Form 706 Estate Tax Return, Portability, and DSUE Practitioner Guide.

Inherited IRAs and beneficiary RMDs

SECURE 2.0 also interacts with the inherited IRA 10-year rule established under SECURE Act 1.0. The interaction of the 10-year rule, the RMD age changes, and whether the original account owner had reached their required beginning date is a complex area that continues to be subject to IRS guidance. Hedge all inherited IRA and beneficiary RMD questions to IRS.gov and the most current IRS guidance; this is an area where the regulatory landscape has shifted multiple times since 2020.

Section 6: Enhanced Catch-Up Contributions for Ages 60-63 (Section 109)

What the provision allows

SECURE 2.0 Act Section 109 enacted a new enhanced catch-up contribution limit for participants who are ages 60, 61, 62, or 63 at any time during the tax year, effective for tax years beginning after December 31, 2024. These participants may make catch-up contributions up to the greater of: (a) the standard catch-up contribution limit (which applies to all participants age 50 and older); or (b) 150% of the standard catch-up contribution limit. Both the standard limit and the enhanced limit adjust annually for inflation per IRC 414(v)(7). Do not state specific dollar amounts; verify the current applicable limits at IRS.gov for each tax year before advising clients.

How this interacts with the Roth catch-up mandate

The Section 109 enhanced catch-up limit for ages 60-63 and the Section 603 Roth catch-up mandate operate on different dimensions simultaneously. Section 109 controls the AMOUNT of the catch-up contribution: participants ages 60-63 may contribute more than other catch-up-eligible participants. Section 603 controls the TAX CHARACTER of the catch-up contribution: high-earning participants above the applicable FICA wage threshold must contribute in Roth (after-tax) form.

For a high-earning participant who is ages 60, 61, 62, or 63 in a plan year beginning on or after January 1, 2026: (1) the enhanced catch-up limit under Section 109 sets the maximum amount they may contribute; and (2) the Roth mandate under Section 603 requires that the catch-up contribution be designated as Roth. Both rules apply simultaneously. Plan administrators must be able to track the enhanced limit for ages 60-63 and route the catch-up amount to a Roth account for high earners in that age bracket.

SIMPLE IRA and SIMPLE 401(k) plans

SECURE 2.0 Act Section 109 also provides an enhanced catch-up limit for ages 60-63 under SIMPLE IRA and SIMPLE 401(k) plans, at a different percentage than the 401(k) plan limit. The applicable percentage and dollar amount for SIMPLE plans: verify at IRS.gov. Do not use the 401(k) enhanced catch-up limits for SIMPLE plan clients without confirming the current SIMPLE-specific limits.

Section 7: Student Loan Matching Contributions (Section 110)

How the provision works

SECURE 2.0 Act Section 110 permits plan sponsors to treat qualified student loan payments (QSLPs) made by an employee as elective deferrals for the purpose of calculating the employer's matching contribution. This provision is effective for plan years beginning after December 31, 2023. It is optional for plan sponsors; they may, but are not required to, adopt this feature.

Under the student loan match feature: an employee who makes a payment on a qualified education loan (as defined in IRC 221(d)(1)) is treated as if they had made an equivalent salary deferral into the plan for matching purposes. The employer then makes a matching contribution calculated as if the QSLP were an actual plan contribution. Critically, the employee does not need to make an actual deferral into the retirement plan to receive the employer match -- the student loan payment itself is the qualifying event that triggers the employer match.

Employee certification

Employees typically self-certify the amount and nature of their qualified student loan payment to their employer. Plan procedures for collecting, verifying, and documenting QSLP certifications should be established by the plan sponsor with TPA and plan counsel assistance before implementing the student loan match feature. IRS Notice 2024-63 provided interim guidance on the mechanics of implementing the student loan match under Section 110, including guidance on employee certification procedures. Hedge all implementation specifics to IRS Notice 2024-63 and IRS.gov; additional IRS guidance may be issued.

Practitioner advisory considerations

The student loan match is an optional plan feature that can be a meaningful employee benefit for plan sponsors who compete for talent with employees carrying student loan debt. Practitioners advising plan sponsors should identify whether the feature makes sense for their client's workforce, and if so, ensure the plan sponsor has: adopted the feature by plan amendment (to be reflected in the December 31, 2026 amendment); implemented a QSLP certification process consistent with IRS Notice 2024-63; and coordinated with the TPA on tracking QSLPs and calculating the match.

Section 8: Pension-Linked Emergency Savings Accounts (Section 127)

What PLESAs are

SECURE 2.0 Act Section 127 permits plan sponsors to add a pension-linked emergency savings account (PLESA) to their retirement plan, effective for plan years beginning after December 31, 2023. PLESAs are a new type of after-tax account that allows eligible employees to set aside funds for emergency expenses within the retirement plan structure, without the early withdrawal penalty that would otherwise apply to retirement plan distributions.

Key PLESA design features

PLESAs are available only to non-highly-compensated employees (NHCEs), as defined in IRC 414(q). Highly compensated employees (HCEs) are not eligible to contribute to a PLESA. Employee contributions to PLESAs are after-tax (not pre-tax or Roth in the traditional sense), and the account balance is capped at a dollar limit per IRS.gov (the cap adjusts periodically; verify the current cap at IRS.gov and SECURE 2.0 Section 127 before advising clients). Distributions from PLESAs are not subject to the 10% early withdrawal penalty under IRC 72(t).

Plan sponsors may auto-enroll eligible employees in the PLESA at a default deferral rate of up to 3% of compensation (hedge to IRS.gov and SECURE 2.0 Section 127 for auto-enrollment requirements specific to PLESAs). The PLESA feature is optional; plan sponsors are not required to offer PLESAs. Practitioners advising plan sponsors who are considering adding a PLESA should review the full PLESA requirements under SECURE 2.0 Section 127 and any IRS guidance issued on IRS.gov before recommending adoption.

Section 9: Small Employer Pension Plan Startup Credit Increase (Section 102)

What changed

SECURE 2.0 Act Section 102 increased the tax credit available to small employers for costs incurred in establishing a new qualified retirement plan, under IRC 45E (the small employer pension plan startup cost credit). The increase is significant and was intended to reduce the out-of-pocket cost barrier for small employers who have never maintained a qualified plan. SECURE 2.0 also added a new employer contribution credit for small employers who make employer contributions to defined contribution plans for the first several years after plan establishment.

The specific credit amounts, eligibility criteria (including the definition of "small employer" under IRC 45E), applicable plan years, and limitations are subject to inflation adjustment and IRS guidance. Do not state specific credit amounts; verify the current applicable credit amounts and eligibility rules at IRS.gov and IRC 45E before advising small employer clients on whether the credit applies to a proposed plan establishment.

Practitioner advisory note

The increased startup credit under Section 102, combined with the employer contribution credit for new plans, materially reduces the net cost of establishing a qualified retirement plan for eligible small employers. Practitioners advising small business clients who do not currently sponsor a retirement plan should evaluate whether these credits, combined with the deduction for employer contributions, make plan establishment advantageous in the current year. Verify current credit amounts at IRS.gov and coordinate with the client's TPA on new plan startup timelines.

Section 10: Practitioner Checklist for 2026 SECURE 2.0 Compliance

Immediate action items (before December 31, 2026)

• Identify all clients who sponsor 401(k), 403(b), SIMPLE IRA, or SEP-IRA plans. For each plan, determine which SECURE 2.0 provisions have been adopted operationally since 2023 and must be reflected in the December 31, 2026 plan amendment. Do not assume a plan without active participation in SECURE 2.0 election features is unaffected; even mandatory provisions (RMD age changes, auto-enrollment for new plans) require plan document amendments.
• Flag the December 31, 2026 plan amendment deadline for all plan sponsor clients. Contact the plan's TPA and plan counsel to confirm the amendment is on their calendar. Allow 60-90 days for TPA and counsel preparation. Do not wait until late in 2026. Source: IRS Notice 2024-2.
• Confirm whether each plan offers a Roth contribution feature. If the plan does not offer Roth contributions, advise the plan sponsor that high-earning participants (those whose prior-year FICA wages from the sponsor exceeded the applicable IRS.gov threshold) cannot make ANY catch-up contributions once the good-faith compliance relief expires on January 1, 2027. The plan must add a Roth feature before that date. Coordinate with the TPA and plan counsel.
• Verify payroll system readiness for the Roth catch-up mandate. The payroll provider and TPA must be able to identify high-earning catch-up-eligible participants, route their catch-up contributions to a Roth account, and code the contributions correctly for W-2 and 1099-R purposes.
• For plans established after December 29, 2022: confirm auto-enrollment is operational for plan years beginning January 1, 2025. Verify the initial deferral percentage and annual escalation feature comply with SECURE 2.0 Section 101. Confirm any applicable exception (church, governmental, new business, small plan) before concluding auto-enrollment is not required. Hedge all exception criteria to IRS.gov.

Ongoing compliance items

• Update RMD calculations and begin-date tracking for all affected participants. The age 73 rule is in effect now for participants who reached age 72 after December 31, 2022. Update beneficiary designation forms, begin-date calculations, and distribution schedules. Hedge all transitional rules to IRS.gov and the current IRC 401(a)(9) regulations. Verify current IRS guidance on beneficiary RMD rules.
• Update plan administration for enhanced catch-up contributions for participants ages 60-63. Confirm the plan and TPA are applying the higher catch-up limit for participants who are ages 60, 61, 62, or 63 during the tax year, for tax years beginning after December 31, 2024. Verify the current dollar limit at IRS.gov annually.
• Advise plan sponsors on student loan match (Section 110) and IRS Notice 2024-63. If the plan sponsor wishes to adopt the student loan match feature, confirm the feature is in the plan document (or added by December 31, 2026), the QSLP certification process is implemented, and the TPA is tracking student loan matches separately. Hedge all implementation specifics to IRS Notice 2024-63 and IRS.gov.
• Evaluate PLESA adoption for plan sponsors whose workforce includes non-highly-compensated employees with emergency savings needs. If adopting a PLESA, confirm the account balance cap per IRS.gov, the auto-enrollment parameters, and the HCE exclusion are properly implemented in the plan document and TPA systems.
• Advise small employer clients on the Section 102 startup credit and employer contribution credit. Evaluate whether eligible small employers who do not currently sponsor a plan should establish one in 2026 to capture the increased startup credit and employer contribution credit. Verify current credit amounts and eligibility at IRS.gov and IRC 45E.
• Document all SECURE 2.0 operational compliance actions in the plan file. The plan document amendment must reflect actual operational practice. Documenting what the plan did operationally since 2023, and under what SECURE 2.0 authority, protects the plan sponsor if the plan document amendment is ever reviewed by the IRS. Good documentation is the foundation of the good-faith compliance position under IRS Notice 2024-2.

Frequently Asked Questions

Related Practitioner Guides

The following guides cover retirement distribution reporting, estate planning, charitable giving strategies, and worker classification rules that practitioners use alongside the SECURE 2.0 analysis.

• IRA Distribution Form 8606 Guide -- SECURE 2.0 changed RMD ages, expanded Roth conversions, added emergency withdrawal rules, and modified Form 8606 reporting obligations; the IRA distribution guide and the SECURE 2.0 guide cover overlapping topics for the same clients and are used together for retirement distribution planning.
• Form 706 Estate Tax Return and Portability Guide -- SECURE 2.0 eliminated lifetime RMDs for Roth 401(k) accounts effective in 2024 and modified the 10-year rule for inherited retirement accounts; these changes interact directly with IRA beneficiary designation strategies and estate planning; the Form 706 guide and the SECURE 2.0 guide are used together for estate planning clients.
• IRC 664 Charitable Remainder Trust Guide -- SECURE 2.0 expanded qualified charitable distributions from IRAs; QCD planning and CRT planning are complementary charitable income strategies often evaluated together; clients with large IRA balances benefit from modeling the SECURE 2.0 QCD expansion against the CRT alternative.
• Employment Tax Worker Classification Guide -- SECURE 2.0 expanded retirement plan access for long-term part-time employees and modified the eligibility rules for certain plans; worker classification as employee versus independent contractor determines which SECURE 2.0 provisions apply; the worker classification and SECURE 2.0 guides serve overlapping small business clients.
• IRC 401(a)/401(k): Qualified Plan Requirements, CODA Mechanics, and OBBBA Changes
• IRC 402: Qualified Plan Distributions, Rollovers, NUA, and Form 1099-R
• IRC 408/408A: Traditional and Roth IRA Contributions, Distributions, and Conversions
• IRC 529: Qualified Tuition Program and 529 Plan Practitioner Guide
• IRC 414: Controlled Group, Affiliated Service Group, and Leased Employee Rules Practitioner Guide