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). SIMPLE and SEP Roth IRA contributions permitted.

Effective 2024: 529-to-Roth rollover allowed (subject to limits). Emergency distributions up to $1,000 penalty-free. 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.

Effective 2026: Roth catch-up requirement for participants whose prior-year FICA wages from the sponsoring employer exceed the Roth catch-up wage threshold ($150,000 based on 2025 wages, for 2026 catch-up contributions).

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 1951-1958, RMD age is 73. Born 1960 or later, RMD age is 75. For individuals born in 1959, the statutory age tests overlap (IRC §401(a)(9)(C)(v)(I) and (II) both describe them), and the final regulations reserve the applicable age (Treas. Reg. §1.401(a)(9)-2(b)(2)(v) is reserved); proposed regulations published July 19, 2024 (89 Fed. Reg. 58644) would set age 73 for 1959 births, but that rule was not final in the regulation text checked on October 29, 2026. Those born in 1959 reach age 73 in 2032. Age 75 applies to those born on or after January 1, 1960 (Treas. Reg. §1.401(a)(9)-2(b)(2)(vi)), who reach 75 in 2035. 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 2024 standard catch-up amount ($7,500), as indexed ($11,250 for 2026). This replaces the standard catch-up ($8,000 for 2026) 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 applies beginning in 2026. SECURE 2.0 requires that catch-up contributions by participants whose prior-year FICA wages from the sponsoring employer exceed $145,000 (indexed; $150,000 for 2026 catch-up contributions, based on 2025 wages) be made as Roth (after-tax) contributions. The statutory effective date is taxable years beginning after December 31, 2023, but Notice 2023-62 provided an administrative transition period through taxable years beginning before January 1, 2026. The final regulations (Treas. Reg. §1.414(v)-2) apply to taxable years beginning after December 31, 2026, with a reasonable, good faith interpretation standard for earlier years.

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; 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 (indexed; $2,600 for 2026), with withdrawals permitted at least once per month and treated as qualified distributions. Separately, participants who self-certify as victims of domestic abuse may withdraw up to the lesser of $10,000 (indexed; $10,500 for 2026) or 50% of the vested account balance without the 10% additional tax. Repayment within three years is permitted and, if made, is treated as a rollover that avoids income tax on the distribution. 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)(C)(v) as amended (applicable age 73 for individuals who attain age 72 after December 31, 2022 and age 73 before January 1, 2033; age 75 for individuals who attain age 74 after December 31, 2032; Treas. Reg. §1.401(a)(9)-2(b)(2) reserves the applicable age for those born in 1959); IRC §402A(d)(5) (Roth 401(k) lifetime 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 the 2024 standard limit, indexed; effective 2025); SECURE 2.0 §603 (Roth catch-up requirement for participants with prior-year FICA wages above $145,000, indexed to $150,000 for 2026; administrative transition under Notice 2023-62); 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 §325 (Roth 401(k) lifetime RMD exemption; effective 2024); SECURE 2.0 §115 (emergency personal expense distributions up to $1,000; distributions after December 31, 2023); SECURE 2.0 §127 (pension-linked emergency savings accounts; $2,500 limit, indexed to $2,600 for 2026; withdrawals at least monthly, treated as qualified distributions under IRC §402A(e)(7)); SECURE 2.0 §314 (domestic abuse distribution; $10,000, indexed to $10,500 for 2026, or 50% of vested balance; self-certification; optional repayment within 3 years; distributions after December 31, 2023); IRS Notice 2023-62 (administrative transition period for the Roth catch-up requirement through taxable years beginning before January 1, 2026); Treas. Reg. §1.414(v)-2 (final regulations; apply to taxable years beginning after December 31, 2026, with reasonable good faith interpretation for earlier years); SECURE 2.0 §101 (IRC §414A - automatic enrollment mandate for new 401(k) and 403(b) plans; initial deferral of at least 3% and not more than 10%; plan years beginning after December 31, 2024, for plans established after December 29, 2022).
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