Page 452 - DCAC Feb 2026 Files

IRS Issued Final Regs Regarding

Mandatory Roth Catch-up

• IRS issued TD 10033 on September 15, 2025, providing final regs regarding the

mandatory catch-up provision contained in SECURE 2.0 Act.

• The final rules generally apply for plan years beginning after 12/31/2026

(2027), rather than 01/01/2026.

• However, the final regulations also permit plans to implement the Roth catch-

up requirement for tax years beginning before 2027 using a reasonable, good-

faith interpretation of statutory provisions. Must implement 01/01/2026.

• Industry professionals are reviewing and interpreting the 94-page regulation

package and additional information is expected in the future.

• Mandatory Roth is not applicable to Special Catch-Up Provision.

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