Retirement Consulting Insights
New Year, New Rules: SECURE 2.0 Considerations for 2025
MARCH 4, 2025
Helping employees save for the future and become retirement-ready is critical. Those who lack a clear path to retirement may slow employer growth, increase healthcare costs, and become dissatisfied as the years pass. This can translate into millions of dollars in costs annually — a financial hit that’s unsustainable for most organizations.
$50,000+
Lack of retirement-readiness in a workforce can impact an organization’s bottom line by more than $50,000 annually for every employee who can’t retire on time.1
Designed to enhance savings opportunities for employees, the SECURE 2.0 Act of 2022 (SECURE 2.0) features more than 90 new mandatory and optional retirement provisions.
Set a SECURE 2.0 Strategy
As several new SECURE 2.0 provisions became effective January 1, 2025, USI Consulting Group’s (USICG’s) experts recommend employers review their retirement plan(s), and consider taking advantage of options that provide employees additional ways to save. USICG provides guidance to help employers:
- Understand the new provisions
- Set a strategy to improve employee savings participation (to boost retirement readiness)
- Identify opportunities to reduce long-term costs to the organization through a workforce that is retirement ready
SECURE 2.0 provisions to focus on in 2025:
Super catch-up contributions
Roth catch-up contributions
Employer contributions treated as Roth
Expanded coverage for LTPT workers
Employer matching contributions on student loan payments
Self-certification of distribution options
Below, we’ve summarized key new mandatory and optional provisions of SECURE 2.0. Access additional details in SECURE 2.0: What Employers Need to Know for 2025.
Super Catch-Up Contributions for Ages 60-63 (Optional)
For older retirement plan participants, the additional catch-up contribution (referred to as the “super catch-up contribution”) allows for increased deferrals between ages 60 and 63. Below is an overview of the catch-up limits for 2025.
Roth Catch-Up Contributions for High-Wage Earners (Mandatory)
Beginning next year on January 1, 2026, participants in 401(k), 403(b) and governmental 457(b) plans who earned more than $145,000 in FICA wages in the prior year will be required to make catch-up contributions on a Roth (after-tax) basis. Participants who earned less than $145,000 in FICA wages for the preceding calendar year must be given the option — but are not required — to make catch-up contributions on a Roth basis.
USICG’s benchmarking studies show 88% of retirement plan sponsors offer Roth catch-up contributions.
Employer Contributions Treated as Roth Contributions (Optional)
Employers may allow plan participants to b. Employers offering this option must follow the IRS’s guidance for the implementation and potential tax impacts for employees. USICG recommends employers consult with trusted tax professionals and payroll providers to weigh the benefits and challenges of the option.
Participants with both pre-tax and Roth contributions have account balances that are 43% higher compared to those with no Roth contributions.3
Expanded Coverage for Long-Term Part-Time (LTPT) Workers (Mandatory)
Beginning January 1, 2025, LTPT employees who are at least 21 years old and have completed at least 500 hours of service in two consecutive years are eligible to contribute to their employers’ 401(k) or 403(b) savings plan. However, employers are not obligated to provide additional matching contributions for LTPT employees due to this rule change.
It's important to note that the employer is responsible for tracking the hours and notifying their service provider of LTPT employees eligible to participate. Rather than tracking hours, some employers are choosing to amend their plan documents to allow all part-time employees to participate.
Employer Matching Contributions on Student Loan Payments (Optional)
In August 2024, the IRS published Notice 2024-63 issuing interim guidance on qualified student loan payment matching contributions to help employees who have not been able to save for retirement because of overwhelming student loan debt. Employers may make matching contributions to the retirement plan based on a participant’s student loan payments, as if those payments were elective deferrals to the plan.
Self-Certification of Hardship Withdrawals and Other Distribution Options (Optional)
Through SECURE 2.0, employers may choose to offer distribution options that allow participants, in times of need, access to retirement funds. Participants can self-certify their eligibility, which reduces employer liability and allows them to respect the privacy of employees facing adversity.
In addition to the hardship distribution option, the following new distribution options are available under SECURE 2.0, and employers may choose to adopt some or all immediately or at a later date:
- Withdrawals for emergency expenses up to $1,000
- Withdrawals for federally declared disasters
- Eligible distributions for domestic abuse victims
- Qualified birth or adoption distributions (QBADs)
How USICG Can Help
SECURE 2.0 brings dozens of new requirements, and it’s important to understand the changes and ongoing IRS and DOL clarifying guidance. USICG can help employers navigate the provisions and implement a strategy to enhance financial wellness programs, increase employee participation, and mitigate the long-term financial impact to the organization.
To learn more, contact your USICG representative, visit our Contact Us page, or reach out to us directly at information@usicg.com.
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1 Prudential, Why Employers Should Care About the Costs of Delayed Retirements, 2019.
2 The $11,250 reflects 150% of the 2025 regular catch-up amount of $7,500.
3 Principal proprietary data, December 2023.
This information is provided solely for educational purposes and is not to be construed as investment, legal or tax advice. Prior to acting on this information, we recommend that you seek independent advice specific to your situation from a qualified investment/legal/tax professional. | xxxx.xxxx.xxxx
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