Mandatory Provisions

Required Minimum Distribution (RMD) Age Increase (2023 & 2033) 

• The RMD age will increase to 73 for individuals who attain the age 72 after December 31, 2022.
• The RMD age will increase to 75 for individuals who attain the age of 74 after December 31, 2032
• The current RMD requirements for those ages 70 ½ and 72 remain in effect.

Qualified Birth Adoption Distribution Repayment Correction (2023)

• The Birth Adoption distribution (a provision from SECURE 1.0) is still available. SECURE 2.0 clarifies that these distributions can be repaid within 3 years of the date of the distribution. Participants who took a birth/adoption distribution prior to SECURE 2.0 have until January 1, 2026, to repay the amount to their account (at participant’s option).

ROTH Catch up Contributions for Higher Wage Earners (January 2026)

• All Age 50 catch-up contributions for individuals with FICA wages in excess of $145,000 (indexed) for the prior year must be made as a Roth contribution. It is important to note that to satisfy this provision, Plans must have a Roth source. If not, age 50 catch-up is still available but only to non-high wage earners. 

In-Plan Roth RMDs (2024)

• This provision eliminates the requirement that participants in qualified plans must take an RMD from ROTH contribution sources during their lifetime.

Optional Provisions 

Terminal Illness Withdrawal Option (2023)

• Allows those diagnosed as terminal ill (within 84 months) to take a withdrawal from their account exempt from the 10% early withdrawal penalty.
• Participants must provide a certified physician’s letter as proof of diagnosis and the distribution can be repaid to the account withing 3 years.

Domestic Abuse Withdrawal Option (2024)

• Withdrawal option that is available over 1-year period beginning on any date on which an individual is a victim of domestic abuse.
• The distribution can be the lesser of $10,000 or 50% of the participant’s vested account balance.
• Exempt from the 10% early withdrawal penalty, and can be repaid to the account within 3 years. 

In-Service Emergency Withdrawal Option (2024) 

• One distribution allowed up to $1,000 per year for those experiencing an unforeseen or immediate financial need related to personal or family emergency. 
• Exempt from the 10% early withdrawal penalty, and can be repaid to the account within 3 years. 
• Those who do not repay the account (through repayment or equal contributions) are not able to take another emergency withdrawal for 3 years. 

Updates to Federally Declared Disaster Withdrawals (Retroactive to 2021)

• Those impacted by a federally declared disaster can take a withdrawal up to $22,000 exempt from the 10% early withdrawal penalty. 
• The limit for loans from the account (due to federally declared disasters) has increased to 100% of the vested account balance/$100,000 and repayments can be delayed for one year. 
• The withdrawal must be taken within 180 days of the disaster declaration. 

Financial Hardship Distribution Sources (2024)

• Source withdrawals for financial hardship distributions from 403(b) plans will include: Elective Deferrals, Qualified nonelective contributions (QNECs), Qualified Employer Matching contributions (QMAC),and earnings on these sources.
• Any employer contribution sources permitted from a plan must be 100% vested.

Roth Employer Contributions (2023)

• Allows employees to designate employer contributions to be taxable now, as opposed to upon distribution. 
• Only fully-vested employer contributions can made as a Roth or Non-Elective.
• Contributions are included within the taxable income the year the contribution is made and are reported using Form 1099-R. Employer Roth contributions are not subject to federal income tax withholding and are not wages for purposes of FICA, or FUTA.
• This is an irrevocable election, but there will be an opportunity to change the designation at least once a year.

Age 60-63 Catch-up Contributions (2025)

• Catch-up contributions for those age 60-63 increased to greater of $10,000 (indexed) or 150% of annual Age 50 catch-up limit.
• In 2026, individuals with FICA wages in excess of $145,000 (indexed) for the prior year must be made as a Roth contribution. It is important to note that to satisfy this provision, Plans must have a Roth source. If not, age 60-63 catch-up is still available but only to non-high wage earners. 

Student Loan Payment Match (2024)

• Employers may elect to provide employer matching contributions on qualified student loan payments in lieu of elective deferral contributions.
• All employees eligible to receive regular match contributions will also be eligible to receive student loan match. 
• Student loan match is the same rate as “regular” matching contributions, and subject to same vesting schedule.
• Student loan match may not exceed current elective deferral limit.
• Employees will certify the amount of loan payments annually and Employers may rely on this certification. 

Qualified Longevity Annuities for Retirees (2023)

• Allows retirees to use up to $200,000 of account balance to purchase a qualified longevity annuity.
• The annuity can have survivor rights.

Nominal Financial Incentives (2023) 

• Employers can now offer employees nominal incentives up to $250 to enroll into a retirement plan. The amount can be split up over time and is not subject to normal contribution rules.

Savers Match (2027) 

• Federal government matching contribution up to $1,000 to eligible worker’s retirement savings for contributions up to $2,000 at a rate of $0.50 for every $1.00 contributed. 

Mandatory Provisions

Required Minimum Distribution (RMD) Age Increase (2023 & 2033) 

• The RMD age will increase to 73 for individuals who attain the age 72 after December 31, 2022.
• The RMD age will increase to 75 for individuals who attain the age of 74 after December 31, 2032
• The current RMD requirements for those ages 70 ½ and 72 remain in effect.

Qualified Birth Adoption Distribution Repayment Correction (2023)

• The Birth Adoption distribution (a provision from Secure 1.0) is still available. Secure 2.0 clarifies that these distributions can be repaid within 3 years of the date of the distribution. Participants who took a birth/adoption distribution prior to SECURE 2.0 have until January 1, 2026, to repay the amount to their account (at participant’s option).

ROTH Catch up Contributions for Higher Wage Earners (January 2026)

• All Age 50 catch-up contributions for individuals with FICA wages in excess of $145,000 (indexed) for the prior year must be made as a Roth contribution. It is important to note that to satisfy this provision, Plans must have a Roth source. If not, age 50 catch-up is still available but only to non-high wage earners. 

In-Plan Roth RMDs (2024)

• This provision eliminates the requirement that participants in qualified plans must take an RMD from ROTH contribution sources during their lifetime.

Long-Term, Part-Time Employees (2025)

• SECURE Act 1.0 extended elective deferral eligibility in 401(k) plans to “long-term part-time” workers with 3 consecutive years of at least 500 hours of service. SECURE 2.0 adds 403(b) plans to this provision and changes the 3-year rule to 2 years. The counting hours for part-time employees begin in 2023 for 401k plans (the industry has requested additional guidance on this.) Current legislation conflicts with the 20-hour exclusion under 403(b) Universal Availability rules, so IRS guidance is also required for 403(b) plans to understand the implication of the change. ADMIN Partners will provide updates on this provision as we learn more.

Optional Provisions 

Terminal Illness Withdrawal Option (2023)

• Allows those diagnosed as terminal ill (within 84 months) to take a withdrawal from their account exempt from the 10% early withdrawal penalty.
• Participants must provide a certified physician’s letter as proof of diagnosis and the distribution can be repaid to the account withing 3 years.

Domestic Abuse Withdrawal Option (2024)

• Withdrawal option that is available over 1-year period beginning on any date on which an individual is a victim of domestic abuse.
• The distribution can be the lesser of $10,000 or 50% of the participant’s vested account balance.
• Exempt from the 10% early withdrawal penalty, and can be repaid to the account within 3 years. 

In-Service Emergency Withdrawal Option (2024) 

• One distribution allowed up to $1,000 per year for those experiencing an unforeseen or immediate financial need related to personal or family emergency. 
• Exempt from the 10% early withdrawal penalty and can be repaid to the account within 3 years. 
• Those who do not repay the account (through repayment or equal contributions) are not able to take another emergency withdrawal for 3 years. 

Updates to Federally Declared Disaster Withdrawals (Retroactive to 2021)

• Those impacted by a federally declared disaster can take a withdrawal up to $22,000 exempt from the 10% early withdrawal penalty. 
• The limit for loans from the account (due to federally declared disasters) has increased to 100% of the vested account balance/$100,000 and repayments can be delayed for one year. 
• The withdrawal must be taken within 180 days of the disaster declaration.

Financial Hardship Distribution Sources (2024)

• Source withdrawals for financial hardship distributions from 403(b) plans will include: Elective Deferrals, Qualified nonelective contributions (QNECs), Qualified Employer Matching contributions (QMAC), and earnings on these sources.
• Any employer contribution sources permitted from a plan must be 100% vested.

Small Balance Cash-Out Limit Increase (2024)

• The small balance cash-out limit has increased from $5,000 to $7,000.
• The provision is only available in plans using a group mutual fund platform or group annuity contract (limit is not indexed for future years). 

Plan-Linked Emergency Savings Account (PLESA) (2024) 

• At this time, few investment providers have implemented this account option as the account management is complex.
• Participant contributions can go into the PLESA until the account balance reaches $2,500 and will be treated as Roth contributions.
• PLESA contributions are matched at the same rate as elective deferrals. 
• The Employer must auto enroll at at level up to 3% and HCEs may not participate.
• Investments are in in principal preservation investments and the provision is only available in plans using a group mutual fund platform or group annuity contract. 
• Emergency distributions are available at least once per month with the first four withdrawals exempt from the 10% early withdrawal penalty and any fees. 
• Upon termination of employment, the account balance may be: Rolled to a Roth source; rolled to a Roth IRA or distributed to participant.

Roth Employer Contributions (2023)

• Allows employees to designate employer contributions to be taxable now, as opposed to upon distribution. 
• Only fully-vested employer contributions can made as a Roth or Non-Elective.
• Contributions are included within the taxable income the year the contribution is made and are reported using Form 1099-R. Employer Roth contributions are not subject to federal income tax withholding and are not wages for purposes of FICA, or FUTA.
• This is an irrevocable election, but there will be an opportunity to change the designation at least once a year.

Student Loan Payment Match (2024)

• Employers may elect to provide employer matching contributions on qualified student loan payments in lieu of elective deferral contributions.
• All employees eligible to receive regular match contributions will also be eligible to receive student loan match. 
• Student loan match is the same rate as “regular” matching contributions, and subject to same vesting schedule.
• Student loan match may not exceed current elective deferral limit.
• Employees will certify the amount of loan payments annually and Employers may rely on this certification.

Age 60-63 Catch-up Contributions (2025)

• Catch-up contributions for those age 60-63 increased to greater of $10,000 (indexed) or 150% of annual Age 50 catch-up limit. 
• In 2026, individuals with FICA wages in excess of $145,000 (indexed) for the prior year must be made as a Roth contribution. It is important to note that to satisfy this provision, Plans must have a Roth source. If not, age 60-63 catch-up is still available but only to non-high wage earners. 

Qualified Longevity Annuities for Retirees (2023)

• Allows retirees to use up to $200,000 of account balance to purchase a qualified longevity annuity.
• The annuity can have survivor rights.

Nominal Financial Incentives (2023) 

• Employers can now offer employees nominal incentives up to $250 to enroll into a retirement plan. The amount can be split up over time and is not subject to normal contribution rules.

Savers Match (2027) 

• Federal government matching contribution up to $1,000 to eligible worker’s retirement savings for contributions up to $2,000 at a rate of $0.50 for every $1.00 contributed.

Mandatory Provisions

Required Minimum Distribution (RMD) Age Increase (2023 & 2033) 

• The RMD age will increase to 73 for individuals who attain the age 72 after December 31, 2022.
• The RMD age will increase to 75 for individuals who attain the age of 74 after December 31, 2032
• The current RMD requirements for those ages 70 ½ and 72 remain in effect.

Qualified Birth Adoption Distribution Repayment Correction (2023)

• The Birth Adoption distribution (a provision from Secure 1.0) is still available. Secure 2.0 clarifies that these distributions can be repaid within 3 years of the date of the distribution. Participants who took a birth/adoption distribution prior to SECURE 2.0 have until January 1, 2026, to repay the amount to their account (at participant’s option).

ROTH Catch up Contributions for Higher Wage Earners (January 2026)

• All Age 50 catch-up contributions for individuals with FICA wages in excess of $145,000 (indexed) for the prior year must be made as a Roth contribution. It is important to note that to satisfy this provision, Plans must have a Roth source. If not, age 50 catch-up is still available but only to non-high wage earners. 

In-Plan Roth RMDs (2024)

• This provision eliminates the requirement that participants in qualified plans must take an RMD from ROTH contribution sources during their lifetime.

Optional Provisions 

Terminal Illness Withdrawal Option (2023)

• Allows those diagnosed as terminal ill (within 84 months) to take a withdrawal from their account exempt from the 10% early withdrawal penalty.
• Participants must provide a certified physician’s letter as proof of diagnosis and the distribution can be repaid to the account withing 3 years.

Domestic Abuse Withdrawal Option (2024)

• Withdrawal option that is available over 1-year period beginning on any date on which an individual is a victim of domestic abuse.
• The distribution can be the lesser of $10,000 or 50% of the participant’s vested account balance.
• Exempt from the 10% early withdrawal penalty and can be repaid to the account within 3 years. 

In-Service Emergency Withdrawal Option (2024) 

• One distribution allowed up to $1,000 per year for those experiencing an unforeseen or immediate financial need related to personal or family emergency. 
• Exempt from the 10% early withdrawal penalty and can be repaid to the account within 3 years. 
• Those who do not repay the account (through repayment or equal contributions) are not able to take another emergency withdrawal for 3 years. 

Updates to Federally Declared Disaster Withdrawals (Retroactive to 2021)

• Those impacted by a federally declared disaster can take a withdrawal up to $22,000 exempt from the 10% early withdrawal penalty. 
• The limit for loans from the account (due to federally declared disasters) has increased to 100% of the vested account balance/$100,000 and repayments can be delayed for one year. 
• The withdrawal must be taken within 180 days of the disaster declaration.

Age 60-63 Catch-up Contributions (2025)

• Catch-up contributions for those age 60-63 increased to greater of $10,000 (indexed) or 150% of annual Age 50 catch-up limit. 
• In 2026, individuals with FICA wages in excess of $145,000 (indexed) for the prior year must be made as a Roth contribution. It is important to note that to satisfy this provision, Plans must have a Roth source. If not, age 60-63 catch-up is still available but only to non-high wage earners. 

Qualified Longevity Annuities for Retirees (2023)

• Allows retirees to use up to $200,000 of account balance to purchase a qualified longevity annuity.
• The annuity can have survivor rights. 

Nominal Financial Incentives (2023) 

• Employers can now offer employees nominal incentives up to $250 to enroll into a retirement plan. The amount can be split up over time and is not subject to normal contribution rules.

Savers Match (2027) 

• Federal government matching contribution up to $1,000 to eligible worker’s retirement savings for contributions up to $2,000 at a rate of $0.50 for every $1.00 contributed.

Mandatory Provisions

Required Minimum Distribution (RMD) Age Increase (2023 & 2033) 

• The RMD age will increase to 73 for individuals who attain the age 72 after December 31, 2022.
• The RMD age will increase to 75 for individuals who attain the age of 74 after December 31, 2032
• The current RMD requirements for those ages 70 ½ and 72 remain in effect.

Qualified Birth Adoption Distribution Repayment Correction (2023)

• The Birth Adoption distribution (a provision from Secure 1.0) is still available. Secure 2.0 clarifies that these distributions can be repaid within 3 years of the date of the distribution. Participants who took a birth/adoption distribution prior to SECURE 2.0 have until January 1, 2026, to repay the amount to their account (at participant’s option).

ROTH Catch up Contributions for Higher Wage Earners (January 2026)

• All Age 50 catch-up contributions for individuals with FICA wages in excess of $145,000 (indexed) for the prior year must be made as a Roth contribution. It is important to note that to satisfy this provision, Plans must have a Roth source. If not, age 50 catch-up is still available but only to non-high wage earners. 

In-Plan Roth RMDs (2024)

• This provision eliminates the requirement that participants in qualified plans must take an RMD from ROTH contribution sources during their lifetime.

Optional Provisions 

Terminal Illness Withdrawal Option (2023)

• Allows those diagnosed as terminal ill (within 84 months) to take a withdrawal from their account exempt from the 10% early withdrawal penalty.
• Participants must provide a certified physician’s letter as proof of diagnosis and the distribution can be repaid to the account withing 3 years

Domestic Abuse Withdrawal Option (2024)

• Withdrawal option that is available over 1-year period beginning on any date on which an individual is a victim of domestic abuse.
• The distribution can be the lesser of $10,000 or 50% of the participant’s vested account balance.
• Exempt from the 10% early withdrawal penalty and can be repaid to the account within 3 years. 

In-Service Emergency Withdrawal Option (2024) 

• One distribution allowed up to $1,000 per year for those experiencing an unforeseen or immediate financial need related to personal or family emergency. 
• Exempt from the 10% early withdrawal penalty and can be repaid to the account within 3 years. 
• Those who do not repay the account (through repayment or equal contributions) are not able to take another emergency withdrawal for 3 years. 

Updates to Federally Declared Disaster Withdrawals (Retroactive to 2021)

• Those impacted by a federally declared disaster can take a withdrawal up to $22,000 exempt from the 10% early withdrawal penalty. 
• The limit for loans from the account (due to federally declared disasters) has increased to 100% of the vested account balance/$100,000 and repayments can be delayed for one year. 
• The withdrawal must be taken within 180 days of the disaster declaration.

Age 60-63 Catch-up Contributions (2025)

• Catch-up contributions for those age 60-63 increased to greater of $10,000 (indexed) or 150% of annual Age 50 catch-up limit. 
• In 2026, individuals with FICA wages in excess of $145,000 (indexed) for the prior year must be made as a Roth contribution. It is important to note that to satisfy this provision, Plans must have a Roth source. If not, age 60-63 catch-up is still available but only to non-high wage earners. 

Student Loan Payment Match (2024)

• Employers may elect to provide employer matching contributions on qualified student loan payments in lieu of elective deferral contributions.
• All employees eligible to receive regular match contributions will also be eligible to receive student loan match. 
• Student loan match is the same rate as “regular” matching contributions, and subject to same vesting schedule.
• Student loan match may not exceed current elective deferral limit.
• Employees will certify the amount of loan payments annually and Employers may rely on this certification.

Qualified Longevity Annuities for Retirees (2023)

• Allows retirees to use up to $200,000 of account balance to purchase a qualified longevity annuity.
• The annuity can have survivor rights.

Nominal Financial Incentives (2023) 

• Employers can now offer employees nominal incentives up to $250 to enroll into a retirement plan. The amount can be split up over time and is not subject to normal contribution rules.

Savers Match (2027) 

• Federal government matching contribution up to $1,000 to eligible worker’s retirement savings for contributions up to $2,000 at a rate of $0.50 for every $1.00 contributed. 

Mandatory Provisions

Required Minimum Distribution (RMD) Age Increase (2023 & 2033) 

• The RMD age will increase to 73 for individuals who attain the age 72 after December 31, 2022.
• The RMD age will increase to 75 for individuals who attain the age of 74 after December 31, 2032
• The current RMD requirements for those ages 70 ½ and 72 remain in effect.

Qualified Birth Adoption Distribution Repayment Correction (2023)

• The Birth Adoption distribution (a provision from Secure 1.0) is still available. Secure 2.0 clarifies that these distributions can be repaid within 3 years of the date of the distribution. Participants who took a birth/adoption distribution prior to SECURE 2.0 have until January 1, 2026, to repay the amount to their account (at participant’s option).

ROTH Catch up Contributions for Higher Wage Earners (January 2026)

• All Age 50 catch-up contributions for individuals with FICA wages in excess of $145,000 (indexed) for the prior year must be made as a Roth contribution. It is important to note that to satisfy this provision, Plans must have a Roth source. If not, age 50 catch-up is still available but only to non-high wage earners. 

In-Plan Roth RMDs (2024)

• This provision eliminates the requirement that participants in qualified plans must take an RMD from ROTH contribution sources during their lifetime.

Optional Provisions 

Terminal Illness Withdrawal Option (2023)

• Allows those diagnosed as terminal ill (within 84 months) to take a withdrawal from their account exempt from the 10% early withdrawal penalty.
• Participants must provide a certified physician’s letter as proof of diagnosis and the distribution can be repaid to the account withing 3 years.

Domestic Abuse Withdrawal Option (2024)

• Withdrawal option that is available over 1-year period beginning on any date on which an individual is a victim of domestic abuse.
• The distribution can be the lesser of $10,000 or 50% of the participant’s vested account balance.
• Exempt from the 10% early withdrawal penalty and can be repaid to the account within 3 years. 

In-Service Emergency Withdrawal Option (2024) 

• One distribution allowed up to $1,000 per year for those experiencing an unforeseen or immediate financial need related to personal or family emergency. 
• Exempt from the 10% early withdrawal penalty and can be repaid to the account within 3 years. 
• Those who do not repay the account (through repayment or equal contributions) are not able to take another emergency withdrawal for 3 years. 

Updates to Federally Declared Disaster Withdrawals (Retroactive to 2021)

• Those impacted by a federally declared disaster can take a withdrawal up to $22,000 exempt from the 10% early withdrawal penalty. 
• The limit for loans from the account (due to federally declared disasters) has increased to 100% of the vested account balance/$100,000 and repayments can be delayed for one year. 
• The withdrawal must be taken within 180 days of the disaster declaration.

Small Balance Cash-Out Limit Increase (2024)

• The small balance cash-out limit has increased from $5,000 to $7,000.
• The provision is only available in plans using a group mutual fund platform or group annuity contract (limit is not indexed for future years).

Plan-Linked Emergency Savings Account (PLESA) (2024) 

• At this time, few investment providers have implemented this account option as the account management is complex.
• Participant contributions can go into the PLESA until the account balance reaches $2,500 and will be treated as Roth contributions.
• PLESA contributions are matched at the same rate as elective deferrals. 
• The Employer must auto enroll at at level up to 3% and HCEs may not participate.
• Investments are in in principal preservation investments and the provision is only available in plans using a group mutual fund platform or group annuity contract. 
• Emergency distributions are available at least once per month with the first four withdrawals exempt from the 10% early withdrawal penalty and any fees. 
• Upon termination of employment, the account balance may be: Rolled to a Roth source; rolled to a Roth IRA or distributed to participant.

Roth Employer Contributions (2023)

• Allows employees to designate employer contributions to be taxable now, as opposed to upon distribution. 
• Only fully-vested employer contributions can made as a Roth or Non-Elective.
• Contributions are included within the taxable income the year the contribution is made and are reported using Form 1099-R. Employer Roth contributions are not subject to federal income tax withholding and are not wages for purposes of FICA, or FUTA.
• This is an irrevocable election, but there will be an opportunity to change the designation at least once a year.

Student Loan Payment Match (2024)

• Employers may elect to provide employer matching contributions on qualified student loan payments in lieu of elective deferral contributions.
• All employees eligible to receive regular match contributions will also be eligible to receive student loan match. 
• Student loan match is the same rate as “regular” matching contributions, and subject to same vesting schedule.
• Student loan match may not exceed current elective deferral limit.
• Employees will certify the amount of loan payments annually and Employers may rely on this certification.

Age 60-63 Catch-up Contributions (2025)

• Catch-up contributions for those age 60-63 increased to greater of $10,000 (indexed) or 150% of annual Age 50 catch-up limit. 
• In 2026, individuals with FICA wages in excess of $145,000 (indexed) for the prior year must be made as a Roth contribution. It is important to note that to satisfy this provision, Plans must have a Roth source. If not, age 60-63 catch-up is still available but only to non-high wage earners. 

Qualified Longevity Annuities for Retirees (2023)

• Allows retirees to use up to $200,000 of account balance to purchase a qualified longevity annuity.
• The annuity can have survivor rights.

Savers Match (2027) 

• Federal government matching contribution up to $1,000 to eligible worker’s retirement savings for contributions up to $2,000 at a rate of $0.50 for every $1.00 contributed. 

Nominal Financial Incentives (2023) 

• Employers can now offer employees nominal incentives up to $250 to enroll into a retirement plan. The amount can be split up over time and is not subject to normal contribution rules.