Roth-Only 401(k) Catch-Up Contribution Timeline for Highly Paid Delayed Two Years

Under SECURE 2.0, starting in 2024, individuals earning $145,000 or more in the prior calendar year were only allowed to make Roth catch-up contributions.

On August 25, 2023, the IRS published Notice 2023-62, putting an “Administrative Transition Period” of two years on the SECURE 2.0 requirement that all participants earning $145,000 or more in the prior calendar year must make all catch-up contributions as Roth.

An “Administrative Transition Period” is an unusual term. It basically means that the IRS will not enforce Section 603 of SECURE 2.0 in relation to forced Roth catch-up contributions for highly paid individuals.

Bottom Line: Thus, individuals earning $145,000+ in 2023 and 2024 may make either Roth or regular catch-up contributions in 2024 and 2025 respectively.