---
title: IRS Issues Final Rules for Catch-Up Contributions to Retirement Plans
description: IRS finalizes SECURE 2.0 rules mandating Roth basis for high-earner catch-up contributions to retirement plans by 2027, with key clarifications on implementation. Effective November 17, 2025.
---

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# [IRS Issues Final Rules for Catch-Up Contributions to Retirement Plans](https://advocacy.naifa.org/govtalk/irs-issues-final-rules-for-catch-up-contributions-to-retirement-plans)

 Written by [NAIFA](https://advocacy.naifa.org/govtalk/author/naifa) | 10/15/25 3:05 PM

On September 16, the Internal Revenue Service (IRS) and Treasury released final regulations implementing the SECURE 2.0 new rules for catch-up contributions to retirement savings plans. The final regulations (TD 10033/RIN 1545-BR11) implement the SECURE 2.0 rule that requires high-paid retirement savers to make their catch-up contributions on a Roth basis.

Generally, the SECURE 2.0 rule requires that as of 2027, catch-up contributions made by those age 50 or older who earn more than $145,000 must be after-tax (with tax-free distributions)—i.e., the Roth rule. The final regulations mostly follow the regulations as proposed, but the final version contains certain clarifications. They include two key clarifications:

1. Prior year FICA wages will determine whether a taxpayer’s income exceeds $145,000, and
2. A plan must include a Roth contribution option for an eligible plan participant who earns over $145,000 to be able to make a catch-up contribution. If the plan does not contain a Roth contribution option, the taxpayer, even if otherwise eligible, would not be permitted to make a catch-up contribution.

The final regulations are effective as of November 17, 2025.

***Prospects***: The final regulations state that plans may implement Roth catch-up contributions before 2027, provided they use a reasonable, good faith interpretation of statutory provisions. And plans may be amended to add the Roth contribution option if they do not already have it.

**NAIFA Staff Contact: **Jayne Fitzgerald – Director – Government Relations, at [jfitzgerald@naifa.org](mailto:jfitzgerald@naifa.org)

[View full post](https://advocacy.naifa.org/govtalk/irs-issues-final-rules-for-catch-up-contributions-to-retirement-plans)

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