Since the SECURE 2.0 Act was passed in December 2022, its provisions have been rolling out over several years. Between May and October 2025, we’ve seen significant clarifications and final rules, especially around catch-up contributions, auto-enrollment, and plan design. Below is a timeline of key developments, followed by action items for plan sponsors and what older rules you can now drop or reassess.

Timeline & Key Developments

2023 — Baseline & foundational changes

• The SECURE 2.0 Act became law on December 29, 2022 and many of its provisions began phasing in starting 2023.
  
• One of the earliest changes was increasing catch-up contributions for those age 50+ from $6,500 to $7,500.
  
• The required minimum distribution (RMD) age was bumped from 72 to 73 for many individuals.

2024 — Intermediate implementation

• Some provisions, such as student loan payment matching, became actionable in 2024.

• The 529 plan rollover to Roth IRA feature (up to $35,000) began in 2024.

2025 — Major new steps, clarifications & final rules

• On January 1, 2025, many auto-enrollment provisions kick in for newly established 401(k)/403(b) plans (those formed after December 29, 2022). Plans must automatically enroll eligible employees at a minimum of 3% and increase by 1% annually until at least 10% (capped at 15%).
• In 2025, super catch-up contributions for those aged 60–63 become available. The limit will be whichever is greater: $10,000 or 150% of the regular age-50+ catch-up limit. For 2025, that works out to $11,250.
• The IRS/Treasury issued final regulations on Roth catch-up contributions in 2025, requiring certain higher-income participants to designate catch-up contributions as Roth (i.e. after-tax).
• The proposed and final regulations for automatic enrollment, notice obligations, eligibility, and deemed Roth elections have continued to be refined in 2025.

• The 2025 cost-of-living adjustments for retirement plans were set: for example, elective deferral limits increased to $23,500.
• The limitation on defined benefit plans rose from $275,000 to $280,000.

• The IRS continues to accept restatement and determination-letter applications through March 31, 2025, for certain defined benefit plans. 

What Is Optional or Can Be Deferred (But You Should Consider)

• Offering super catch-up contributions: Not required, but beneficial. Plans that include catch-up may elect to adopt the higher limits for ages 60–63.
• Deemed Roth election approach: Plans may automatically treat catch-up contributions of impacted participants as Roth (unless they opt out), easing administrative burden.
• Auto-enrollment for older plans: The mandate applies only to newly established plans (post-Dec 2022). Legacy plans are not forced to adopt it.

• Accelerating implementation: Some sponsors may voluntarily adopt some features (e.g. Roth catch-up, auto-enrollment) earlier, under “reasonable good-faith interpretations.”

What’s No Longer or Less Relevant / Superseded (Review These)

• The old catch-up limit of $6,500 for age 50+ is obsolete; for 2023 onward, the base is $7,500 (with super catch-ups for 60–63).
• The previous RMD age of 72 is mostly superseded for new cohorts. Under SECURE 2.0, many are required to begin RMDs at age 73 or later.
• Some older rules regarding part-time employee eligibility (three-year rule) have changed: now, part-time employees meeting 500 hours over two consecutive years may qualify.

Key Takeaways & To-Do List

1. Review your plan’s establishment date — if your plan was created after December 29, 2022, auto-enrollment will be mandatory beginning in 2025 (unless exceptions apply).
2. Amend plan documents to allow super catch-up for ages 60–63 (optional but often advantageous).
3. Update administration systems to support Roth catch-up contributions (especially for higher earners) and handle the transition rules.
4. Adjust W-2 and payroll processes for de minimis incentives and reporting changes.
5. Check defined benefit plans for restatement requirements by March 31, 2025.
6. Reassess older assumptions (e.g. old catch-up limits, older RMD rules, part-time eligibility) to ensure your plan is aligned with current law.