Final Treasury regulations released in September 2025, alongside new SPARK Institute best practices, confirm the importance of coordination between payroll and recordkeeping systems as SECURE 2.0’s designated Roth age-based catch-up mandate takes effect in 2026.
Plan sponsors that want to provide designated Roth age-based catch-up contributions in their plan are encouraged to complete an internal readiness review to ensure payroll and recordkeeping systems are aligned before the first 2026 payroll cycle. Plan Adviser released an article, Roth Catch-Up Playbook, to provide additional guidance for plan consultants.
Some things to consider include:
- Plan document: If desired, confirm deemed Roth deferral source is available or amend your plan to allow before year-end 2025.
- Payroll and recordkeeping alignment: Use a “yes/no” indicator to flag earners above $150,000 and verify Roth file formats are properly coded.
- Election method: Consider combining elections to minimize confusion for participants.
- Communications: Provide clear notices to employees age 50+ about how Roth-only catch-ups apply.
- Fiduciary documentation: Record committee decisions and maintain audit-ready confirmations.
Maintaining a compliance calendar and testing data feeds early in the year can help identify any mismatches between systems, helping protect both the plan and participants.
Reach out to your Corebridge representative for access to exclusive plan sponsor resources to help confirm Roth capability, identify affected participants, and document process updates for audit readiness.
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