On September 16, 2025, the Internal Revenue Service (IRS) issued final regulations to reflect statutory changes under Section 603 of SECURE 2.0, which generally require that catch-up contributions made by participants in 401(k), 403(b) and 457(b) plans whose FICA wages exceed $145,000 (indexed) must be made as Roth contributions. While the final regulations provide relief for employers, the IRS did not delay the general effective date for compliance, which remains January 1, 2026 for plans that are not collectively bargained multi-employer plans. This alert focuses on the new rules as they relate to 401(k), 403(b), and 457(b) plans. It does not address collectively bargained multi-employer plans.