The SECURE 2.0 Act: Provisions and Effective-Date Tracker

The SECURE 2.0 Act of 2022 (P.L. 117-328, enacted December 29, 2022) staggers roughly 90 retirement provisions across a decade of effective dates, from tax year 2023 through 2033. This tracker maps 23 provisions most relevant to retirees and savers to their operative year, the governing rule, and a named primary source, with the required minimum distribution (RMD) beginning age moving from 72 to 73 for individuals who reach 72 after December 31, 2022, and to 75 for individuals who reach 74 after December 31, 2032 (Source: IRS Publication 590-B, 2025; CRS IF12750).

How to read this tracker

SECURE 2.0 is not a single switch. It is a schedule. Congress attached roughly 90 sections to Division T of the Consolidated Appropriations Act, 2023, and gave many of them different trigger dates (Source: Senate Finance Committee section-by-section summary, December 19, 2022). Some rules took effect for tax years after the December 29, 2022 enactment date. Others were tied to plan years beginning after December 31, 2023 or December 31, 2024. A handful reach out to 2027 and even 2033.

The organizing logic here is deterministic, not statistical. For each provision, the effective year is the calendar year of the first tax or plan year the operative rule applies to, decoded from the statutory or regulatory “beginning after” trigger. The only genuine calculations in this report are the 150 percent enhanced-catch-up formula and the Saver’s Match 50 percent formula, both of which are cross-checked against IRS-published values below.

Readers tracking their own required minimum distributions may also find the companion reference at Q3 Advisors’ RMD 2026 guide useful, and those weighing Roth conversions in light of the new Roth designated-account RMD treatment can review the retirement tax window overview.

Master provision tracker

The table below lists 23 provisions affecting retirees and savers, each with its SECURE 2.0 section, the Internal Revenue Code section it amends, the governing rule, the first effective year, who it affects, and a named source. It is not exhaustive of the full Act.

Effective-year rollup

Grouping the same provisions by first operative year shows how the rollout concentrated in 2024 and 2025, with three later cliffs in 2026, 2027, and 2033.

Note: provision 1 (RMD age) contributes to both 2023 (age 73) and 2033 (age 75); provision 4 (the pre-1987 403(b) age-75 rule) is a long-standing grandfather rule, not a SECURE 2.0 change, and is excluded from the rollup counts above.

Required minimum distributions: the age change in detail

SECURE 2.0 Section 107 raised the RMD applicable age, which determines the required beginning date, from 72 to 73, and then to 75, phased by date of birth (Source: CRS IF12750). The applicable age is 73 for an individual who attains age 72 after December 31, 2022 and attains age 73 before January 1, 2033, effective for distributions required after December 31, 2022 under Section 107(e). The applicable age is 75 for an individual who attains age 74 after December 31, 2032, meaning individuals born in 1960 or later (Source: CRS IF12750).

IRS Publication 590-B (2025) states: “If you reach age 72 after December 31, 2022, you must begin receiving required minimum distributions by April 1 of the year following the year you reach the age 73.” Prior thresholds were age 72 for tax years 2020 through 2022 and age 70.5 for 2019 and earlier (Source: IRS Publication 590-B, 2025).

Applicable age by birth date

The IRS RMD final regulations (TD 10001, 89 FR 58886, published July 19, 2024) set the birth-year mapping below. The regulations became effective September 17, 2024 and apply to distribution calendar years beginning on or after January 1, 2025 (Source: Federal Register document 2024-14542).

Individuals born in 1959 use applicable age 73. A statutory drafting overlap on that birth year was resolved by proposed regulation 89 FR 58644 (Source: Federal Register final regs 2024-14542).

The missed-RMD excise tax

Under SECURE 2.0 Section 302, for taxable years beginning after December 29, 2022, the excise tax on a missed RMD equals 25 percent of the shortfall, the amount by which the RMD exceeds the amount actually distributed. This reduced the prior 50 percent excise tax under IRC Section 4974 (Source: IRS, Internal Revenue Bulletin 2024-33). The IRS RMD FAQs (updated December 10, 2024) state that the amount not withdrawn “may be subject to an excise tax of 25%, 10% if the RMD is timely corrected within two years” (Source: IRS RMD FAQs).

The final regulations describe a two-tier structure: a default 25 percent of the shortfall, reduced to 10 percent if the taxpayer receives the shortfall distribution and files a corrected return within the correction window. That window ends on the earliest of the date a notice of deficiency is mailed, the date the tax is assessed, or the last day of the second taxable year following the year of the shortfall (Source: Federal Register final regs 2024-14542).

Roth designated accounts and lifetime RMDs

SECURE 2.0 Section 325 amended IRC Section 402A to add a new paragraph (d)(5) providing that lifetime RMD rules do not apply to a designated Roth account, applicable to taxable years beginning after December 31, 2023 (Source: IRS, Internal Revenue Bulletin 2024-33). In effect, this extended to designated Roth 401(k), 403(b), and 457(b) accounts the treatment Roth IRAs already had. The IRS RMD FAQs confirm that RMD rules “do not apply to Roth IRAs or Designated Roth accounts while the owner is alive,” though RMD rules do apply to beneficiaries after the account owner’s death (Source: IRS RMD FAQs; CRS IF12750).

Catch-up contributions: two distinct provisions

SECURE 2.0 created two separate catch-up rules that are often conflated. Section 109 raises the catch-up limit for participants ages 60 through 63. Section 603 requires certain higher earners to make catch-up contributions on a Roth basis. They have different effective dates and different mechanics.

Enhanced catch-up for ages 60-63 (Section 109)

For a catch-up-eligible participant who attains age 60, 61, 62, or 63 during the taxable year, the catch-up limit is the greater of $10,000 or 150 percent of the otherwise-applicable age-50 catch-up limit, indexed for inflation. The rule applies to 401(k), 403(b), governmental 457(b), and the federal Thrift Savings Plan, and amends IRC 414(v)(2)(E), effective for taxable years beginning after December 31, 2024 (Source: IRS). The worked figures below cross-check the 150 percent formula against the IRS-published amounts.

For 2025 the enhanced amount is $11,250 for 401(k), 403(b), 457, and TSP, versus the regular $7,500 age-50 catch-up, and $5,250 for SIMPLE plans versus the regular $3,500 (Source: IRS Notice 2024-80). For 2026, the IRS states the higher catch-up “remains $11,250” for 401(k)-type plans even though 150 percent of the increased $8,000 regular catch-up would be $12,000; the held figure reflects COLA rounding. The SIMPLE ages 60-63 amount is $5,250 for 2026, the regular age-50 catch-up is $8,000 for 401(k)-type plans and $4,000 for SIMPLE, and the 401(k) elective deferral limit for 2026 is $24,500 (Source: IRS Notice 2025-67; IRS “401(k) limit increases to $24,500 for 2026”).

Mandatory Roth catch-up for higher earners (Section 603)

Under IRC 414(v)(7)(A), an eligible participant whose FICA wages for the preceding calendar year from the employer sponsoring the plan exceed the threshold must make any catch-up contributions as designated Roth contributions (Source: IRS; Federal Register final rule 2025-17865). The wages measured are Social Security (FICA) wages reported in Box 3 of Form W-2, not Box 5 Medicare wages, and only wages from the plan-sponsoring employer count (Source: Federal Register 2025-17865).

The statutory base threshold is $145,000, adjusted annually in the same manner as IRC 415(d)(1)(A), with any increase that is not a multiple of $5,000 rounded down to the next lower multiple of $5,000 (codified at IRC 414(v)(7)(E)). The 2025 threshold is $150,000, increased from the statutory $145,000; this 2025 wage figure determines whether a participant’s 2026 catch-up contributions must be Roth (Source: IRS Notice 2025-67).

The effective date is layered. Section 603(c) set taxable years beginning after December 31, 2023, but IRS Notice 2023-62 granted a two-year administrative transition period. The final regulations set general applicability to contributions in taxable years beginning after December 31, 2026 (Source: IRS newsroom, final regulations on the Roth catch-up rule). In practice, the requirement operates for the 2026 tax and plan year based on 2025 wages exceeding $150,000, with the regulations’ formal general applicability date after December 31, 2026. Later applicability dates apply for applicable collectively bargained plans, governmental plans, and eligible governmental 457(b) plans (Source: Federal Register 2025-17865). The final regulations carry document number 2025-17865, RIN 1545-BR11, publication date September 16, 2025, and a rule effective date of November 17, 2025 (Source: Federal Register 2025-17865).

Roth and savings expansions

529-to-Roth rollovers (Section 126)

SECURE 2.0 added a $35,000 lifetime limit on rollovers from a 529 qualified tuition program to a Roth IRA of the same beneficiary, effective for distributions made after December 31, 2023 (Source: IRS “529 plans: Questions and answers”; IRS Pub 590-A, 2025). The conditions, all from the IRS 529 Q&A, are: a direct trustee-to-trustee transfer; an annual rollover capped at the Roth IRA annual contribution limit reduced by other IRA contributions that year; the 529 account must have been open at least 15 years as of the distribution date; and the rollover may not exceed contributions plus attributable earnings made to the 529 more than five years before the distribution date (Source: IRS “529 plans: Questions and answers”). The IRS has not issued comprehensive regulations resolving all mechanics, such as whether a change of beneficiary resets the 15-year clock.

Student-loan matching (Section 110)

Employers may, at their option, make matching contributions on account of employees’ Qualified Student Loan Payments under 401(k), 403(b), SIMPLE IRA, and governmental 457(b) plans (Source: IRS Notice 2024-63). The statutory provision is effective for plan years beginning after December 31, 2023, and a QSLP match cannot be made for loan payments paid on or before December 31, 2023. Notice 2024-63 regulatory guidance applies for plan years beginning after December 31, 2024; for earlier plan years, sponsors may rely on a good-faith reasonable interpretation of Section 110 (Source: IRS Notice 2024-63). All employees eligible for elective-deferral matches must be eligible for QSLP matches (Source: IRS Notice 2024-63, citing IRC 401(m)(13)(A)(iii)).

Saver’s Match (Section 103)

Beginning in tax year 2027, SECURE 2.0 replaces the Saver’s Credit with a federal matching contribution of 50 percent on up to $2,000 of retirement contributions per individual, a maximum match of $1,000 per person, deposited into the taxpayer’s retirement account rather than paid as a tax credit (Source: CRS IF11159). Eligible contributions include traditional and Roth IRAs and defined-contribution plans such as 401(k)s.

Income thresholds are cost-of-living adjusted for years after 2027, but the $2,000 maximum contribution amount is not indexed for inflation (Source: CRS IF11159).

Automatic enrollment for new plans (Section 101)

SECURE 2.0 added IRC Section 414A, which requires most 401(k) cash-or-deferred arrangements and 403(b) salary-reduction arrangements established after the December 29, 2022 enactment date to include an automatic contribution arrangement (Source: 26 U.S.C. Section 414A). The initial default deferral is a uniform percentage “not less than 3 percent and not more than 10 percent” of compensation in the first year of participation, escalating by 1 percentage point each subsequent plan year up to a final level of “at least 10 percent, but not more than 15 percent” (Source: 26 U.S.C. Section 414A). A transitional rule substitutes 10 percent for 15 percent as the ceiling for plan years ending before January 1, 2025. The rule is effective for plan years beginning after December 31, 2024 (Source: 26 U.S.C. Section 414A; IRS Notice 2024-2).

Exemptions, verbatim from the statute, include SIMPLE 401(k) plans, plans established before December 29, 2022, governmental plans, church plans, new businesses in existence less than three years, and small employers that normally employed 10 or fewer employees. Participants may opt out or elect a different percentage (Source: 26 U.S.C. Section 414A).

QCD indexing (Section 307)

SECURE 2.0 indexed the previously fixed $100,000 annual qualified charitable distribution limit and created a new one-time QCD to a split-interest entity (a charitable remainder unitrust, charitable remainder annuity trust, or charitable gift annuity) with a base of $50,000, indexed. The indexed amounts reported by industry sources citing IRS COLA announcements are below.

Annual indexing began in 2024; the one-time split-interest QCD is effective for tax years beginning after December 29, 2022 (Source: Senate Finance section-by-section, Sec. 307; industry sources citing IRS COLA releases). These indexed dollar amounts are drawn from industry summaries of IRS COLA releases rather than a single primary quote, and each year should be confirmed against the specific IRS notice.

Worked examples

Example A: RMD beginning age

An individual born in 1953 attains age 72 after December 31, 2022 and age 73 before January 1, 2033, so the applicable age is 73 (Source: 89 FR 58886). An individual born in 1962 attains age 74 after December 31, 2032, so the applicable age is 75 (Source: CRS IF12750). Readers can cross-reference the mechanics with Q3 Advisors’ RMD 2026 reference.

Example B: enhanced catch-up formula

For 2025, the regular age-50 401(k) catch-up is $7,500. The Section 109 formula is the greater of $10,000 or 150 percent of $7,500, which is $11,250. The IRS-published ages 60-63 amount is $11,250, matching the formula (Source: IRS Notice 2024-80).

Example C: Saver’s Match

A single filer with modified AGI below $20,500 who contributes $2,000 to an IRA in 2027 would receive a 50 percent match of $1,000 deposited into the account (Source: CRS IF11159). The $2,000 contribution cap that drives the maximum match is not indexed for inflation.

Frequently asked questions

When was the SECURE 2.0 Act enacted?

The SECURE 2.0 Act of 2022 was enacted December 29, 2022 as Division T of the Consolidated Appropriations Act, 2023, P.L. 117-328 (Source: Senate Finance Committee section-by-section summary; Congress.gov).

What is the RMD beginning age now?

The applicable age is 73 for an individual who attains age 72 after December 31, 2022 and 73 before January 1, 2033, and 75 for an individual who attains age 74 after December 31, 2032 (Source: CRS IF12750; IRS Pub 590-B, 2025).

Which SECURE 2.0 section raised the RMD age?

Section 107, which amends IRC 401(a)(9)(C). An early CRS search snippet labeled it Section 106; the enacted and IRS-cited section is 107 (Source: IRS; Federal Register).

What is the applicable age for someone born in 1959?

Age 73. A statutory overlap on that birth year was resolved by proposed regulation 89 FR 58644 (Source: Federal Register final regs 2024-14542).

What is the applicable age for someone born in 1960 or later?

Age 75, because such individuals attain age 74 after December 31, 2032 (Source: CRS IF12750; 89 FR 58886).

What is the penalty for missing an RMD under SECURE 2.0?

For taxable years beginning after December 29, 2022, the excise tax is 25 percent of the shortfall, reduced from the prior 50 percent (Source: IRS, Internal Revenue Bulletin 2024-33).

Can the missed-RMD penalty be reduced further?

Yes. It is reduced to 10 percent of the shortfall if the RMD is timely corrected within the two-year correction window (Source: IRS RMD FAQs, updated December 10, 2024).

Do designated Roth 401(k) accounts still require lifetime RMDs?

No. Section 325 eliminated lifetime RMDs for designated Roth accounts effective for taxable years beginning after December 31, 2023 (Source: IRS, Internal Revenue Bulletin 2024-33; CRS IF12750).

What is the enhanced catch-up for ages 60-63?

The greater of $10,000 or 150 percent of the age-50 catch-up, indexed, effective for taxable years beginning after December 31, 2024 (Source: IRS).

How much is the ages 60-63 catch-up for 2025 and 2026?

$11,250 for 401(k), 403(b), 457, and TSP in both 2025 and 2026, and $5,250 for SIMPLE plans in both years (Source: IRS Notice 2024-80; Notice 2025-67).

Why is the 2026 enhanced catch-up $11,250 and not $12,000?

The 150 percent formula on the $8,000 regular catch-up would produce $12,000, but the IRS states the amount “remains $11,250” for 2026 due to COLA rounding rules (Source: IRS Notice 2025-67).

Who must make catch-up contributions as Roth?

An eligible participant whose prior-year FICA wages (Form W-2 Box 3) from the plan-sponsoring employer exceed the threshold must make catch-up contributions as designated Roth (Source: Federal Register 2025-17865).

What is the Roth catch-up wage threshold?

The statutory base is $145,000, indexed in $5,000 increments; the 2025 threshold is $150,000, which governs whether 2026 catch-up contributions must be Roth (Source: IRS Notice 2025-67).

When does the mandatory Roth catch-up rule take effect?

The statute set 2024, IRS Notice 2023-62 granted a two-year transition, and the final regulations set general applicability to contributions in taxable years beginning after December 31, 2026, with 2026 as the practical operative year (Source: IRS newsroom, final regulations; Federal Register 2025-17865).

What is the 529-to-Roth rollover limit?

A $35,000 lifetime cap per beneficiary, effective for distributions after December 31, 2023 (Source: IRS 529 Q&A; Pub 590-A, 2025).

What are the conditions for a 529-to-Roth rollover?

A direct trustee-to-trustee transfer, an annual cap at the Roth contribution limit, a 529 account open at least 15 years, and exclusion of contributions made within the prior five years (Source: IRS 529 Q&A).

What is the Saver’s Match?

A federal 50 percent match on up to $2,000 of retirement contributions per person, a maximum $1,000, deposited into the account, effective 2027 and replacing the Saver’s Credit (Source: CRS IF11159).

Is student-loan matching required?

No. It is optional. Employers may match qualified student-loan payments as if elective deferrals, for plan years beginning after December 31, 2023 (Source: IRS Notice 2024-63).

What are the auto-enrollment default rates for new plans?

An initial deferral of 3 percent to 10 percent, escalating 1 percentage point per year to at least 10 percent but not more than 15 percent, effective for plan years beginning after December 31, 2024 (Source: 26 U.S.C. 414A; IRS Notice 2024-2).

Which employers are exempt from the auto-enrollment mandate?

SIMPLE 401(k) plans, plans established before December 29, 2022, governmental plans, church plans, businesses less than three years old, and small employers with 10 or fewer employees (Source: 26 U.S.C. 414A).

Did the mandatory cash-out limit change?

Yes. Section 304 raised the force-out ceiling from $5,000 to $7,000 for distributions after December 31, 2023, optional for sponsors to adopt (Source: Senate Finance section-by-section).

Was the QCD limit indexed?

Yes. Section 307 indexed the annual $100,000 QCD limit and created a one-time $50,000 split-interest QCD, both indexed; reported amounts were $108,000 and $54,000 for 2025 (Source: industry sources citing IRS COLA releases).

Did the small-employer plan startup credit change?

Yes. Section 102 raised the credit from 50 percent to 100 percent of qualified startup costs for employers with 50 or fewer employees, up to $5,000 per year, effective for tax years beginning after December 31, 2022 (Source: Senate Finance section-by-section).

Sources

IRS Publication 590-B (2025), https://www.irs.gov/publications/p590b. IRS Publication 590-A (2025), https://www.irs.gov/publications/p590a. IRS Retirement Plan and IRA Required Minimum Distributions FAQs (updated Dec 10, 2024), https://www.irs.gov/retirement-plans/retirement-plan-and-ira-required-minimum-distributions-faqs. IRS Internal Revenue Bulletin 2024-33, https://www.irs.gov/irb/2024-33_IRB. IRS Internal Revenue Bulletin 2025-40, https://www.irs.gov/irb/2025-40_IRB. IRS Notice 2024-80, https://www.irs.gov/pub/irs-drop/n-24-80.pdf. IRS Notice 2025-67, https://www.irs.gov/pub/irs-drop/n-25-67.pdf. IRS Notice 2023-62, https://www.irs.gov/pub/irs-drop/n-23-62.pdf. IRS Notice 2024-2, https://www.irs.gov/pub/irs-drop/n-24-02.pdf. IRS Notice 2024-63, https://www.irs.gov/pub/irs-drop/n-24-63.pdf. IRS Notice 2024-65, https://www.irs.gov/pub/irs-drop/n-24-65.pdf. IRS “401(k) limit increases to $24,500 for 2026,” https://www.irs.gov/newsroom/401k-limit-increases-to-24500-for-2026-ira-limit-increases-to-7500. IRS “Treasury, IRS issue final regulations on new Roth catch-up rule,” https://www.irs.gov/newsroom/treasury-irs-issue-final-regulations-on-new-roth-catch-up-rule-other-secure-2point0-act-provisions. IRS “529 plans: Questions and answers,” https://www.irs.gov/newsroom/529-plans-questions-and-answers. IRS FS-2024-18, https://www.irs.gov/newsroom/secure-2-point-0-act-changes-affect-how-businesses-complete-forms-w-2. Federal Register “Required Minimum Distributions,” document 2024-14542 (July 19, 2024, TD 10001, 89 FR 58886), https://www.federalregister.gov/documents/2024/07/19/2024-14542/required-minimum-distributions; govinfo mirror https://www.govinfo.gov/content/pkg/FR-2024-07-19/html/2024-14542.htm. Federal Register “Catch-Up Contributions,” document 2025-17865 (Sept 16, 2025, RIN 1545-BR11), https://www.federalregister.gov/documents/2025/09/16/2025-17865/catch-up-contributions. 26 U.S.C. Section 414A, https://www.law.cornell.edu/uscode/text/26/414A. Congress.gov P.L. 117-328 bill text, https://www.congress.gov/bill/117th-congress/house-bill/2617/text. CRS IF12750, https://www.everycrsreport.com/reports/IF12750.html. CRS IF11159, https://www.everycrsreport.com/reports/IF11159.html. Senate Finance Committee SECURE 2.0 section-by-section summary (Dec 19, 2022). DOL/EBSA PLESA FAQs, https://www.dol.gov/agencies/ebsa/about-ebsa/our-activities/resource-center/faqs/pension-linked-emergency-savings-accounts. Related Q3 Advisors references: https://q3adv.com/required-minimum-distributions-2026/, https://q3adv.com/the-retirement-tax-window/, https://q3adv.com/retirement-contribution-limits-2026/, https://q3adv.com/secure-2-0-act-provisions/.

About the author

Disclaimer