SECURE 2.0 Act: Every Major Retirement Rule Change

RMD Age 73/75 • Super Catch-Up 60-63 • 529-to-Roth Rollover • Auto-Enrollment • Emergency Savings
P.L. 117-328IRC §401(a)(9)IRC §414(v)
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SECURE 2.0 (P.L. 117-328, enacted December 29, 2022) made over 90 changes to retirement plan rules. Most took effect in 2023, 2024, or 2025. This guide covers every provision with material tax impact for individuals and plan sponsors - organized by effective date rather than by section number, which is how practitioners actually need to use it.

The Biggest Changes by Year

Effective 2023: RMD age raised from 72 to 73. Roth employer matching contributions now permitted. Penalty for missed RMDs reduced from 50% to 25% (10% if corrected promptly). Emergency distributions up to $1,000 penalty-free.

Effective 2024: 529-to-Roth rollover allowed (subject to limits). SIMPLE and SEP Roth IRA contributions permitted. Matching contributions for student loan payments. Domestic abuse withdrawal exception.

Effective 2025: Super catch-up contributions for ages 60-63 ($11,250 vs. standard $7,500). Automatic enrollment requirement for new 401(k) and 403(b) plans. Long-term part-time employee eligibility expanded. Roth catch-up requirement for earners above $145,000.

Effective 2033: RMD age raised again to 75 for those born in 1960 or later.

RMD Age: 73 Now, 75 Later

SECURE 2.0 raised the required beginning date for RMDs. The age depends on birth year: born 1951-1959, RMD age is 73. Born 1960 or later, RMD age is 75 (effective 2033 when those born in 1960 turn 73). The first RMD can be delayed to April 1 of the year following the year you reach RMD age - but taking two RMDs in one year has tax consequences. Roth IRAs remain exempt from RMDs during the owner's lifetime (this did not change). Roth 401(k) accounts are now also exempt from RMDs during the owner's lifetime, effective 2024.

Super Catch-Up: Ages 60-63

Effective 2025, participants aged 60, 61, 62, or 63 can contribute an enhanced catch-up amount of the greater of $10,000 or 150% of the standard catch-up limit (resulting in approximately $11,250 for 2026 - verify with IRS inflation adjustment). This replaces the standard $7,500 catch-up only for those specific ages. At age 64 and beyond, the contribution reverts to the standard catch-up amount. This "super catch-up window" is designed to help pre-retirees maximize retirement savings in the years just before retirement.

The Roth catch-up requirement for high earners has been delayed. SECURE 2.0 required that catch-up contributions by participants earning over $145,000 (indexed) must be made as Roth (after-tax) contributions starting in 2024. The IRS issued Notice 2023-75 delaying this requirement while guidance is developed. Verify the current effective date with a tax advisor or the IRS before the next plan year.

529-to-Roth IRA Rollover

Effective 2024, unused 529 plan funds can be rolled to a Roth IRA for the same beneficiary, subject to: the 529 account must be at least 15 years old; the contribution cannot exceed the annual Roth IRA contribution limit for the year; lifetime limit of $35,000 per beneficiary; the recipient must have earned income at least equal to the rollover amount; and the amount cannot include contributions or earnings from the past 5 years. This eliminates the primary objection to overfunding 529 plans - that unused funds would be stuck.

Emergency Savings and Domestic Abuse Withdrawals

Effective 2024, plans can offer pension-linked emergency savings accounts allowing contributions up to $2,500, with the first four withdrawals per year penalty-free. Separately, participants who self-certify as victims of domestic abuse may withdraw up to the lesser of $10,000 or 50% of the vested account balance penalty-free. The amounts must be repaid within three years to avoid tax. These provisions address the "leakage" problem - people taking early distributions because they have no other emergency fund.

Authority: SECURE 2.0 Act of 2022, P.L. 117-328, Division T (Consolidated Appropriations Act, 2023; enacted December 29, 2022; over 90 retirement provisions); IRC §401(a)(9) as amended (RMD age 73 for those born 1951-1959; age 75 for those born 1960 and later effective 2033; Roth 401(k) RMD exemption); IRC §4974 as amended (reduced penalty for missed RMDs - from 50% to 25%; reduced to 10% if corrected within correction window); IRC §414(v) as amended (catch-up contribution limits; super catch-up for ages 60-63 - greater of $10,000 or 150% of standard limit; effective 2025); SECURE 2.0 §126 (Roth catch-up requirement for earners above $145,000 indexed; delayed by Notice 2023-75); SECURE 2.0 §126 (529-to-Roth rollover; 15-year account requirement; $35,000 lifetime limit; annual Roth contribution limit applies; effective 2024); SECURE 2.0 §115 (Roth 401(k) RMD exemption; effective 2024); SECURE 2.0 §127 (pension-linked emergency savings accounts; $2,500 limit; four penalty-free withdrawals per year); SECURE 2.0 §314 (domestic abuse distribution; $10,000 or 50% of vested balance; self-certification; 3-year repayment; effective 2024); IRS Notice 2023-75 (implementation delay for Roth catch-up requirement; transition relief); SECURE 2.0 §350 (automatic enrollment mandate for new 401(k) and 403(b) plans; 3% minimum deferral; effective 2025 for plans established after 2022).
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