# 2025-00350: Government Forces Rich Retirees Into Roth Catch-Up Contributions

2025-00350, Catch-Up Contributions, is a Federal Register proposed rule from an unnamed agency published 2025-01-13, effective 2024-01-01; PRIA reads it as touching household money (as of 2026-06-11).

- Canonical: https://policyrisk.com/federal-register/2025-00350
- As of: 2026-06-11
- Plain-text twin of the page above; the HTML and this file carry the same facts.

## Facts
- Document number: 2025-00350
- Title: Catch-Up Contributions
- Type: Proposed Rule
- Agencies: unknown
- Citation: unknown
- Published: 2025-01-13
- Effective: 2024-01-01
- Comments close: not stated
- Significant: no
- Touches household money: yes
- Regulation identifier numbers: none
- Last updated: 2026-06-11

## In one line

Government Forces Rich Retirees Into Roth Catch-Up Contributions

## Summary

Starting soon, people aged 50 and older who save extra money for retirement (called catch-up contributions) will have new rules thanks to the SECURE 2.0 Act. Some of these extra savings must now be made as Roth contributions, which means paying taxes now but enjoying tax-free money later. Employers, workers, and plan managers should get ready and share their thoughts by March 14, 2025, before a public hearing on April 7.

## Abstract

This document sets forth proposed regulations that would provide guidance for retirement plans that permit participants who have attained age 50 to make additional elective deferrals that are catch-up contributions. The proposed regulations reflect statutory changes made by the SECURE 2.0 Act of 2022, including the requirement that catch-up contributions made by certain catch-up eligible participants must be designated Roth contributions. The proposed regulations would affect participants in, beneficiaries of, employers maintaining, and administrators of certain retirement plans. This document also provides notice of a public hearing.

## Effects PRIA read

- Roth Requirement for High Earners: cost, medium. If your employer paid you more than $145,000 in FICA wages in the prior calendar year, any catch-up contributions you make must be designated Roth contributions (taxed now, tax-free later). The $145,000 wage threshold is subject to cost-of-living adjustments and the SECURE 2.0 changes apply to taxa…
- Plans May Deem Pre-Tax Elections Roth: benefit, low. For taxable years beginning after December 31, 2023, a plan may provide that a participant who is subject to the Roth catch-up requirement is deemed to have irrevocably designated any catch-up contributions as Roth contributions, and the plan must record them in a designated Roth account and includ…
- Higher Catch-Up Limits at Ages 60–63: benefit, medium. For taxable years beginning after December 31, 2024, participants who attain age 60, 61, 62, or 63 during the year may be permitted higher catch-up limits: 150% of the otherwise applicable dollar catch-up limit (for example, $11,250 = 150% of $7,500 for non-SIMPLE plans, and $5,250 = 150% of $3,500…
- Higher SIMPLE Catch-Up for Very Small Employers: mixed, medium. For taxable years beginning after December 31, 2023, certain SIMPLE plans sponsored by eligible very small employers (for example, plans that had no more than 25 employees with $5,000 compensation in the prior year) may use an increased catch-up limit equal to 110% of the 2024 SIMPLE catch-up limit…
- Two-Year Administrative Transition Relief: benefit, low. The Treasury treats the first two taxable years beginning after December 31, 2023 as an administrative transition period for the Roth catch-up requirement; during that period, catch-up contributions by participants who are subject to the Roth catch-up requirement will be treated as satisfying the r…
- Plans Not Required to Offer Roth Programs: cost, medium. The proposed rules do not require an employer plan to include a qualified Roth contribution program. If a plan does not include a Roth program, participants who are subject to the Roth catch-up requirement would not be permitted to make catch-up contributions under that plan (the maximum permitted…
- Roth Contributions Made Earlier Count: benefit, low. The proposed rules allow designated Roth contributions made earlier in the year (before a limit is reached) to be counted toward satisfying the Roth catch-up requirement; if a participant's total designated Roth elective deferrals during the year equal or exceed the catch-up amount, the Roth catch-…
- No Aggregation of FICA Wages Across Employers: benefit, low. For a participant in a plan maintained by more than one employer (including a multiemployer plan), the participant's FICA wages from one participating employer for the prior calendar year are not aggregated with FICA wages from another participating employer for purposes of determining whether the…
- Puerto Rico Catch-Up Limit Exception: benefit, low. An applicable employer plan that covers employees in both the United States and Puerto Rico will not fail nondiscrimination requirements merely because it allows participants subject to the Puerto Rico limit to make catch-up contributions only up to that Puerto Rico limit; for taxable years beginni…

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## Sources
- [2025-00350 on federalregister.gov](https://www.federalregister.gov/documents/2025/01/13/2025-00350/catch-up-contributions)
- [2025-00350 as published (PDF)](https://www.govinfo.gov/content/pkg/FR-2025-01-13/pdf/2025-00350.pdf)

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Source: PRIA, https://policyrisk.com/federal-register/2025-00350 (as of 2026-06-11).
