SECURE 2.0 Act — Complete Practitioner Guide
Complete guide to SECURE 2.0 Act provisions — RMD age changes, super catch-up contributions, Roth employer contributions, 529-to-Roth rollovers, and student loan matching. Updated for 2026.
SECURE 2.0 Act — Key Provisions Summary
| SECURE 2.0 Provision | Effective Date | Description |
|---|---|---|
| RMD age increased to 73 | 2023 | RMD age increased from 72 to 73; increases to 75 in 2033 |
| Super catch-up (age 60-63) | 2025 | Greater of $10,000 or 150% of regular catch-up for 401(k) |
| Roth employer contributions | 2023 | Employers can make matching contributions to Roth accounts |
| 529-to-Roth rollover | 2024 | Up to $35,000 lifetime rollover from 529 to Roth IRA |
| Student loan matching | 2024 | Employers can match student loan payments with 401(k) contributions |
| Emergency savings accounts | 2024 | Employers can offer emergency savings accounts linked to 401(k) |
| Automatic enrollment | 2025 | New 401(k) plans must auto-enroll employees at 3%-10% |
| SIMPLE IRA catch-up increase | 2025 | SIMPLE IRA catch-up increased to $3,500 (age 50+); $5,250 (age 60-63) |
| SEP/SIMPLE Roth option | 2023 | SEP and SIMPLE IRAs can now have Roth option |
| Qualified longevity annuity contracts | 2023 | QLAC limit increased to $200,000 |
Source: SECURE 2.0 Act of 2022 (Div. T of Consolidated Appropriations Act, 2023); IRC §401(k); §408; §529
The RMD age increase: SECURE 2.0 increased the RMD age from 72 to 73 starting in 2023, and will increase it to 75 starting in 2033. This gives retirees more time to let their retirement accounts grow tax-deferred before being required to take distributions. Practitioners should update RMD calculations for all clients who turned 72 in 2022 or later — they may have an extra year before their first RMD is required.
529-to-Roth IRA Rollover — Planning Opportunity
| 529-to-Roth Rollover Rule | Requirement | Limit |
|---|---|---|
| Account age | 529 account must be at least 15 years old | N/A |
| Beneficiary | Rollover must be to Roth IRA of 529 beneficiary | Cannot roll to parent's Roth IRA |
| Annual limit | Subject to annual Roth IRA contribution limit ($7,000 in 2026) | $7,000/year |
| Lifetime limit | $35,000 lifetime per beneficiary | $35,000 total |
| Income limits | Not subject to Roth IRA income limits | No income phase-out |
| Contribution history | Amount rolled over cannot exceed contributions made in prior 5 years | N/A |
Source: SECURE 2.0 Act §126; IRC §529(c)(3)(E)
The 529-to-Roth strategy: For clients with overfunded 529 accounts (where the beneficiary received a scholarship, chose a less expensive school, or did not attend college), the 529-to-Roth rollover allows up to $35,000 to be rolled to the beneficiary's Roth IRA — tax-free and penalty-free. This is a significant planning opportunity for families with leftover 529 balances. Practitioners should identify all clients with 529 accounts and model the rollover opportunity.
Student Loan Matching — A New Employee Benefit
Starting in 2024, employers can treat employee student loan payments as elective deferrals for purposes of employer matching contributions. This means employees who are paying down student loans (and cannot afford to contribute to their 401(k)) can still receive employer matching contributions — based on their student loan payments rather than 401(k) contributions.
Example: An employee earns $80,000 and pays $5,000/year in student loan payments. The employer matches 50% of contributions up to 6% of salary ($4,800). Under SECURE 2.0, the employer can match the student loan payments — providing a $2,500 employer contribution even though the employee made no 401(k) contributions. This is a powerful recruitment and retention tool for employers, and a significant benefit for employees with student loan debt. Case Study: Dr. Sarah K., physician, age 32. Student loan balance: $280,000. Annual loan payments: $24,000. Employer: non-profit hospital. Previously not contributing to 403(b) due to loan payments. After student loan matching: employer contributes $4,800/year to 403(b); over 10 years (with 6% growth): $63,000 in additional retirement savings. Practitioner fee: $1,500. ROI: 42:1 over 10 years.
SECURE 2.0 Act — Key Provisions Reference Table
| Provision | Effective Date | IRC Section | Key Change |
|---|---|---|---|
| RMD age increase to 73 | 2023 | §401(a)(9) | RMD age increased from 72 to 73 |
| RMD age increase to 75 | 2033 | §401(a)(9) | RMD age increases again to 75 |
| Catch-up contribution increase (age 50+) | 2025 | §414(v) | 401(k) catch-up: $7,500 (indexed) |
| Super catch-up (age 60–63) | 2025 | §414(v) | Higher catch-up: $11,250 for ages 60–63 |
| Roth catch-up required (income >$145K) | 2026 | §414(v)(7) | High earners must make catch-up as Roth |
| 529-to-Roth rollover | 2024 | §529(c)(3)(E) | Up to $35,000 lifetime rollover to Roth IRA |
| Emergency savings accounts | 2024 | §402A | Employers can offer emergency savings linked to 401(k) |
| Student loan matching | 2024 | §401(m) | Employers can match student loan payments as retirement contributions |
| Auto-enrollment requirement | 2025 | §401(k)(15) | New plans must auto-enroll at 3–10% |
| Penalty-free withdrawals (domestic abuse) | 2024 | §72(t) | Up to $10,000 penalty-free for domestic abuse survivors |
| SIMPLE IRA contribution increase | 2024 | §408(p) | SIMPLE IRA limits increased by 10% for small employers |
| Qualified longevity annuity contracts (QLACs) | 2023 | §1.401(a)(9)-5 | QLAC limit increased to $200,000 |
Source: SECURE 2.0 Act of 2022 (P.L. 117-328); IRS Notice 2024-2
SECURE 2.0 contains over 90 provisions affecting retirement plans, IRAs, and related tax rules. The provisions phase in over multiple years — practitioners must track which provisions are effective for each tax year. IRS Notice 2024-2 provides guidance on many of the key provisions.
Practitioner Planning Checklist — SECURE 2.0
- Update RMD calculations for all clients born in 1951 or later. The RMD age is now 73 (increased from 72). Clients who turned 72 in 2022 or earlier are still subject to the old rules. Clients turning 73 in 2023 or later use the new age.
- Identify clients eligible for the super catch-up contribution (ages 60–63). In 2025 and beyond, participants aged 60–63 can contribute an additional $11,250 to 401(k) plans (vs. $7,500 for other catch-up eligible participants). This is a significant planning opportunity for clients approaching retirement.
- Review Roth catch-up requirement for high earners. Beginning in 2026, employees earning more than $145,000 (indexed) must make catch-up contributions as Roth contributions. Advise clients to update their 401(k) elections before the 2026 deadline.
- Evaluate 529-to-Roth rollovers for clients with overfunded 529 accounts. Beneficiaries can roll up to $35,000 lifetime from a 529 to a Roth IRA (subject to annual Roth contribution limits and a 15-year holding period). Ideal for clients whose children did not use all 529 funds.
- Advise small business clients on auto-enrollment requirements. New 401(k) and 403(b) plans established after December 29, 2022 must include automatic enrollment starting in 2025. Existing plans are grandfathered. Review all new plan setups.
- Review student loan matching for employer clients. Employers can now treat employee student loan payments as elective deferrals for matching purposes. This is a valuable recruiting tool for employers with younger workforces.
- Update beneficiary designations for clients with inherited IRAs. SECURE 1.0 and 2.0 significantly changed the rules for inherited IRAs. Non-spouse beneficiaries generally must distribute inherited IRAs within 10 years. Review all inherited IRA situations.
- Model the impact of delayed RMDs on estate plans. Pushing RMDs to age 75 (effective 2033) allows more tax-deferred growth but may result in larger RMDs later. Model the long-term impact for clients with large IRA balances.
Frequently Asked Questions
The information on this page is intended for licensed tax professionals (CPAs, EAs, and tax attorneys) and is provided for educational and research purposes only. Tax law is complex and fact-specific — all strategies discussed are subject to limitations, phase-outs, and conditions that may not apply to every client situation. Practitioners should independently verify all information against current IRS guidance, Treasury Regulations, and applicable state law before advising clients. This content does not constitute legal or tax advice.
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