On September 16, 2025, the Department of the Treasury and the Internal Revenue Service (IRS) issued final rules implementing SECURE 2.0 Act provisions on catch-up contributions. As part of the final rules—in addition to the Roth catch-up rules reviewed in our previous blog, “Roth Catch-Up Contribution Final Rules: Takeaways for Employers”—increased “super” catch-up contribution limits were also discussed for employees turning ages 60-63 during the calendar year.

Proposed rules were previously issued on January 10, 2025, providing guidance on catch-up contributions and automatic enrollment requirements. See our earlier blog post, “SECURE 2.0 Update: IRS Issues Proposed Rules for Qualified Retirement Plans (Part One)—Catch-Up Contributions,” for a summary of the proposed rules.

The 2026 inflation adjusted amounts for standard and catch-up contribution limits are as follows.

• All participants can defer up to $24,500.
• In addition to that amount, participants ages 50-59 and 64+ can defer an additional $8,000 as catch-up.
• For ages 60-63, the $8,000 limit doesn’t apply; instead, ages 60-63 can defer an additional $11,250 super catch-up, indexed for inflation in future years.

Super Catch-Up Basics

Under Internal Revenue Code Section 414(v), plans may allow participants in 401(k), 403(b) and governmental 457(b) plans who are age 50 or older to make catch-up contributions to their retirement plan accounts, in addition to regular deferrals.

If a plan chooses to offer super catch-up contributions, beginning January 1, 2025, employees who turn ages 60, 61, 62 or 63 during the calendar year are eligible to make increased catch-up contributions (the greater of $10,000 or 150% of the standard catch-up limit). For 2026, the amount was determined to be up to $11,250 (PLANSPONSOR explains why the catch-up calculation for 2026 was different than it was for 2025). As an example, in 2026, if a participant turns 62 on March 1, they are eligible to make a total contribution of up to $35,750 ($24,500 standard contribution + $11,250 super catch-up contribution).

The super catch-up limits no longer apply to participants at the beginning of the taxable year in which they turn age 64; then, the standard limit will apply.

Different rules apply to SIMPLE plans and are not discussed in this blog post.

Final Rule Clarifications

The final rules make several additional administrative clarifications regarding optional catch-up contributions, Roth contributions, and 403(b) and governmental 457(b) plans.

• No super catch-up feature is okay. Plans are not required to allow super catch-up contributions, but if they choose to allow them, the plan document must be updated to make clear that the plan permits them.
• Roth applicability. If a plan elects super catch-up contributions, those contributions are subject to the Roth catch-up contribution requirement in the final rules.
• 403(b) plans. Certain 403(b) plans can allow employees with at least 15 years of service to make special catch-up contributions up to $15,000. Quarles explains, “a 403(b) plan may allow participants to make both (1) the special 15-year catch-up contributions, and (2) age-based catch-up contributions (i.e., the age 50+ catch-up and age 60–63 ‘super catch-up’) in the same year. In such cases, any catch-up amounts will be applied first to the 15-year special catch-up, and then to the age-based catch-up limits. The age 60–63 super catch-up is available in addition to the 15-year catch-up.”
• Governmental 457(b) plans. Governmental 457(b) plans may elect to offer super catch-up contributions for those ages 60-63. The additional catch-up contributions to a governmental 457(b) plan made during the three years prior to normal retirement age are not subject to the Roth-only requirement, and only contributions exceeding that limit must be made on a Roth basis.

Effective Date Applicability and Plan Amendments

In some cases, effective dates and plan amendments vary by type of plan.

Applicability Dates

Though plans may have begun electing super catch-up contributions in 2025, the final rules don’t apply until January 1, 2027. Prior to the applicability date of the final rules, a reasonable, good faith interpretation standard applies with respect to the provisions in the rules.

The final rules do not provide a later applicability date for governmental and collectively bargained plans for super catch-up contributions, unlike the Roth catch-up rules.

Plan Amendments

The final rules defer to IRS Notice 2024-2 for deadlines to make required plan amendments.

Most 401(k) and 403(b) plans have until December 31, 2026 to amend plan documents to include any required plan language. This deadline also applies to plans that have already adopted super catch-up contributions for the 2025 plan year. For a collectively bargained 403(b) plan of a tax-exempt organization, the deadline for plan amendments is December 31, 2028. For 403(b) plans maintained by a public school, the deadline is December 31, 2029.

All collectively bargained plans have until December 31, 2028 to amend their plan documents to incorporate any required changes.

Governmental 457(b) plans have until the later of December 31, 2029 or, if applicable, the first day of the first plan year beginning more than 180 days after the date of notification by the Secretary of the Treasury that the plan was administered in a manner that is inconsistent with the requirements of Internal Revenue Code Section 457(b) to amend their plan.

Seyfarth says, “Moving forward, plan sponsors would have until the end of the plan year in which the increased catch-up limit is adopted to amend their plans.” 

Universal Availability and Controlled Groups

Though allowing super catch-up contributions is an optional provision, controlled groups have less choice in deciding whether to offer super catch-up contributions to eligible employees. According to the preamble of the final rules, if any plan in a controlled group offers super catch-up contributions, then all plans in the controlled group (subject to any exceptions) must offer them to comply with the final rule’s catch-up contribution universal availability requirement to satisfy nondiscrimination rules.

The universal availability requirement says plans must offer all participants eligible for catch-up contributions an opportunity to make the same dollar amount of catch-up contributions to satisfy nondiscrimination rules. The requirement applies to all plans in the same controlled group; however, according to the final rules, a plan does not fail to satisfy the universal availability requirement solely because certain employees (e.g., collectively bargained employees) are not given the opportunity to make catch-up contributions or can’t make them to the same extent as other employees. 

Next Steps for Employers

Employers should take the following steps to prepare for changes resulting from the super catch-up provisions.

• Make sure plan documents are up to date. The plan document must clearly reflect if super catch-up contributions are allowed for employees ages 60-63.
• Communicate with participants. Explain the super catch-up provision for contributions, the availability of higher catch-up limits for eligible participants and document distribution.
• Update payroll systems. Develop processes and update systems to track eligible participants.
• Consult with service providers. Discuss required administrative updates, plan amendments and implementation questions with service providers.

Watch for additional updates on SECURE 2.0 provisions in our SECURE 2.0 Toolkit.

Developed by International Foundation Information Center staff. This does not constitute legal advice. Please consult your plan professionals for legal advice.