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SECURE Act 2.0

SECURE Act 2.0

SECURE Act 2.0

Jason Stolz CLTC, CRPC, DIA, CAA

The SECURE Act 2.0 — formally the Consolidated Appropriations Act of 2023, signed into law on December 29, 2022 — represents the most comprehensive overhaul of retirement savings policy since the original SECURE Act of 2019. With more than 90 individual provisions affecting IRAs, 401(k)s, 403(b)s, Roth accounts, annuities, and inherited retirement assets, the legislation touches virtually every dimension of retirement planning strategy for both account owners and their beneficiaries. Its effects have been rolling out across multiple years — the most significant provisions began taking effect in 2023 and 2024, with important additional changes arriving in 2025, 2026, and 2027 — making it essential for retirees, pre-retirees, and financial planners to understand not just what changed but when each change became operative and how the changes interact with each other across a household’s full financial picture.

The headline provision — increasing the required minimum distribution starting age — is both the most widely reported and the most frequently misunderstood. Raising the age at which distributions must begin from 72 to 73 does not simply give account owners more time for tax-deferred growth. It compresses all future required distributions into a shorter window, which can produce larger mandatory withdrawals later in life that push income into higher brackets, trigger Medicare premium surcharges, and accelerate the taxation of Social Security benefits. Without deliberate planning during the window between retirement and the new RMD starting age, the benefit of delayed distributions can become a tax acceleration mechanism rather than the relief it superficially appears to be. Understanding how to use the new RMD window strategically — through Roth conversions, Qualified Charitable Distributions, bracket-topping distributions, and annuity positioning — is the core of tax-aware retirement planning under SECURE 2.0.

Beyond the RMD age change, SECURE 2.0 introduced meaningful structural changes: expanded Roth options for workplace plans, new contribution opportunities for workers approaching retirement, student loan matching provisions for employers, emergency savings account access within 401(k) plans, 529-to-Roth IRA rollovers, enhanced QLAC limits, and automatic enrollment requirements for new workplace plans. The interaction between these provisions and the existing landscape of tax-deferred and tax-free savings vehicles creates a more complex — but also more opportunity-rich — planning environment than most households have faced in decades. This page covers the key provisions in practical detail, with specific attention to how each affects retirement income planning, tax management, and beneficiary strategy. This content is educational; readers should consult a qualified tax advisor or financial professional for guidance on their specific situation. For the beneficiary planning implications of SECURE Act rules, our dedicated resource on the stretch IRA ten-year rule covers inherited IRA distribution requirements in full detail, and our guide on RMDs after SECURE 2.0 covers the required minimum distribution mechanics for account owners specifically.

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SECURE Act 2.0 — Key Provisions by Effective Date

Provision Effective Date Who It Affects Planning Implication
RMD age increased to 73 January 1, 2023 Those born 1951–1959 More time before mandatory withdrawals; window for Roth conversions and bracket-topping distributions
RMD penalty reduced (50% → 25%) January 1, 2023 All retirement account owners subject to RMDs Reduced to 10% if corrected promptly; still avoidable with proper planning and distribution tracking
Roth 401(k) / 403(b) no longer subject to RMDs January 1, 2024 Roth account holders in employer plans Aligns Roth employer accounts with Roth IRA treatment; allows Roth funds to grow undisturbed through retirement
Student loan payment matching January 1, 2024 Employers and employees with student debt Employer can match student loan payments as retirement contributions; allows simultaneous debt paydown and retirement saving
529-to-Roth IRA rollovers January 1, 2024 529 account beneficiaries with unused education funds Up to $35,000 lifetime rollover after 15-year holding period; subject to annual Roth contribution limits
Super catch-up contributions (ages 60–63) January 1, 2025 Workers aged 60–63 with employer retirement plans Greater of $10,000 or 150% of regular catch-up limit; inflation-indexed; largest last-minute savings window in retirement plan history
Automatic enrollment for new plans January 1, 2025 Employees at companies with new 401(k)/403(b) plans (established after Dec 29, 2022) 3–10% auto-enrollment with 1% annual escalation; increases retirement participation rates nationwide
Long-term part-time workers (2 years) January 1, 2025 Part-time workers with 500+ hours in two consecutive years Reduced from 3-year requirement; expands retirement plan access for part-time workforce
Mandatory Roth catch-up for high earners January 1, 2026 (transition period throughout 2026) Employees earning $145,000+ in FICA wages in prior year All catch-up contributions must be designated Roth (after-tax); plans without Roth option cannot accept these employees’ catch-ups
Federal Saver’s Match 2027 Lower- and middle-income retirement savers Replaces Saver’s Credit with direct federal matching contributions (up to $1,000) deposited into retirement accounts
RMD age increases to 75 2033 Those born in 1960 or later Extends deferral window further; additional time for Roth conversion and income management strategies before mandatory distributions begin

This table summarizes major provisions. SECURE Act 2.0 contains more than 90 individual provisions, many with specific conditions, income thresholds, and plan-type variations. Specific contribution limits are indexed for inflation and change annually. Readers should confirm current limits and applicability with a tax professional or current IRS guidance. Tax laws change; individual situations vary significantly.

The RMD Age Change — Opportunity, Tax Trap, or Both

The increase in the required minimum distribution starting age is the most visible provision in SECURE Act 2.0, and it creates a genuine planning opportunity — but only when used with deliberate strategy. For individuals born between 1951 and 1959, required minimum distributions now begin at age 73 rather than 72. For those born in 1960 or later, the starting age will increase further to 75 beginning in 2033. The immediate implication is straightforward: account owners have one or more additional years during which no mandatory distribution is required, during which the account continues to grow tax-deferred.

The planning challenge is subtler. Every year that distributions are deferred is a year during which pre-tax account balances continue to grow — which means the account balance that future required distributions are calculated from is larger. When RMDs do begin at 73 (or 75), the account balance may be meaningfully larger than it would have been at 72, producing larger mandatory annual distributions that push more income into higher brackets. This is the “tax trap” version of the RMD delay: a retiree who does nothing with the additional years before mandatory distributions begin may find that the total lifetime tax burden on their retirement assets is higher than it would have been under the old rules, because the forced distributions are larger and arrive at ages when the retiree may have fewer deductions or less flexibility to manage taxable income. Our resource on RMDs after SECURE 2.0 covers the calculation mechanics in full detail, and our guide on how long will my savings last in retirement covers the broader income sustainability framework that puts RMD timing in context.

Using the Pre-RMD Window Strategically

The period between retirement and the required minimum distribution starting age — now potentially up to a decade or more for those retiring in their early 60s — is one of the most valuable tax planning windows in the retirement timeline. During this window, taxable income from wages has dropped or disappeared, RMDs have not yet begun, and Social Security may or may not have started. The result is often a period of genuinely lower marginal tax rates compared to both the working years preceding it and the high-RMD years that follow. This window is the optimal time for Roth conversions: deliberately moving money from pre-tax accounts (traditional IRAs, 401(k)s) to Roth accounts by treating the converted amount as taxable income in the conversion year, paying tax now at presumably favorable rates, and enjoying tax-free growth and tax-free distributions in all subsequent years.

The Roth conversion strategy during the pre-RMD window is the planning response that most directly addresses the RMD accumulation problem. By reducing the pre-tax account balance through conversions before mandatory distributions begin, the retiree simultaneously reduces the future RMD obligation and creates a tax-free Roth balance that can be drawn from in years when additional taxable income would be particularly costly — for example, years when unexpected income from other sources might push Medicare premiums up through IRMAA surcharges. Our resource on Roth conversions covers the full mechanics and optimal timing framework, and our guide on IRMAA planning strategies covers how Medicare premium surcharges interact with income management decisions during the pre-RMD and RMD years.

Roth 401(k) Accounts Are Now RMD-Free — A Major Structural Change

One of the most practically significant provisions of SECURE Act 2.0 — and one of the least discussed in mainstream coverage — is the elimination of required minimum distributions from Roth accounts within employer retirement plans, effective January 1, 2024. Before SECURE 2.0, Roth 401(k) and Roth 403(b) accounts were subject to RMDs during the account owner’s lifetime, which distinguished them unfavorably from Roth IRAs (which have never been subject to owner-lifetime RMDs). This created a planning inefficiency: account holders who wanted to avoid RMDs from their Roth employer plan balances had to roll those funds into a Roth IRA before RMDs began. SECURE 2.0 eliminates this requirement entirely — Roth employer plan accounts are now exempt from lifetime RMD requirements, aligning them with Roth IRA treatment.

The planning implication is significant for anyone with meaningful Roth 401(k) or Roth 403(b) balances: those funds can now remain in the employer plan, growing tax-free, without any mandatory distribution obligation. This creates an additional pool of tax-free assets that can be drawn from strategically in years when additional taxable income would be particularly costly, or left entirely intact to grow for the benefit of beneficiaries. Combined with the broader expansion of Roth access in employer plans — the ability for employers to offer Roth treatment for matching and non-elective contributions, the new super catch-up contributions, and the mandatory Roth catch-up requirement for higher earners starting in 2026 — the trajectory of SECURE 2.0 is clearly toward substantially larger Roth balances in the retirement accounts of Americans who take advantage of these provisions.

Super Catch-Up Contributions for Ages 60 to 63

SECURE Act 2.0 created a new catch-up contribution tier specifically for workers in the 60-to-63 age range — a period when career earnings are often at their peak, children are typically financially independent, mortgage balances may be reduced, and the retirement horizon is near enough to make maximum savings urgently relevant. Starting in 2025, workers who are ages 60, 61, 62, or 63 during the calendar year can make catch-up contributions to eligible employer retirement plans of the greater of $10,000 or 150% of the regular catch-up limit (which is subject to annual inflation indexing). For 2025, this “super catch-up” limit is $11,250 — substantially larger than the standard age-50-and-older catch-up contribution.

The super catch-up provision is one of the few SECURE 2.0 changes that creates an unambiguously favorable opportunity for the workers it benefits, with no significant offsetting tradeoffs for most participants. Workers in this age range who have retirement accounts at work should confirm with their plan administrator and HR department that the plan has been amended to support the super catch-up contribution — not all plans adopted this provision immediately — and should update their annual contribution elections accordingly. The combination of the regular employee deferral limit, the standard catch-up available to workers 50 and older, and the super catch-up for those 60-63 means that retirement savers in this age range can make the largest annual contributions to workplace retirement accounts that have ever been permitted in the tax code.

Mandatory Roth Catch-Up for High Earners — Effective 2026

One of the more complex operational provisions of SECURE Act 2.0 is the requirement, effective January 1, 2026, that employees whose FICA wages from their employer exceeded $145,000 (indexed for inflation) in the prior calendar year must make all catch-up contributions to employer retirement plans as Roth (after-tax) contributions rather than pre-tax contributions. This mandatory Roth treatment applies regardless of the employee’s preference for pre-tax or Roth contributions — if the income threshold is met, all catch-up contributions must go into the Roth bucket. The IRS issued final regulations on this provision in September 2025, establishing that good-faith compliance is acceptable throughout 2026 as plans implement the required administrative changes, with final regulation enforcement applying for taxable years beginning after December 31, 2026.

The practical implication of this provision is that high-earning employees who previously made pre-tax catch-up contributions — reducing current taxable income — will no longer be able to do so. Instead, their catch-up contributions will be made with after-tax dollars and will grow tax-free, providing a Roth benefit in future years but eliminating the current-year tax deduction. Employers whose plans do not currently offer a Roth contribution option must add one before 2026 or risk being unable to accept catch-up contributions from affected high earners — which effectively forces most plans to add Roth capability if they haven’t already done so. This provision, combined with the broader Roth expansion throughout SECURE 2.0, represents a clear legislative preference for shifting retirement savings into after-tax Roth structures over time.

Qualified Charitable Distributions — Still One of the Most Powerful Tax Tools

Qualified Charitable Distributions (QCDs) allow IRA owners who are age 70½ or older to transfer funds directly from their IRA to qualified charities, excluding the transferred amount from adjusted gross income even though no charitable deduction is taken. The QCD provision was not substantially changed by SECURE Act 2.0, but it becomes increasingly strategic in the SECURE 2.0 planning environment because of its ability to satisfy part or all of the required minimum distribution obligation while simultaneously reducing adjusted gross income below what a standard distribution-and-deduction approach would achieve.

The adjusted gross income reduction from a QCD is more powerful than a regular charitable deduction for many retirees because it reduces MAGI before the calculation of Medicare IRMAA surcharges, before the determination of whether Social Security benefits are taxable, and before various income-based phase-outs and credits that depend on AGI rather than taxable income. A retiree who would otherwise take a $30,000 RMD, pay income tax on it, and then make a $20,000 charitable donation as an itemized deduction achieves a meaningfully less favorable tax outcome than one who transfers $20,000 of that RMD directly to a qualified charity as a QCD and takes only $10,000 as taxable income. Our resource on qualified charitable distributions covers the full mechanics, eligibility requirements, and annual limits for this strategy, which continues to be one of the most consistently valuable tax-reduction tools available to charitably inclined retirees regardless of SECURE 2.0 provisions.

The 72(t) Distribution Strategy — Still Available for Early Retirees

For retirees who need income from IRA accounts before age 59½ without triggering the standard 10% early withdrawal penalty, the Section 72(t) distribution strategy — which requires substantially equal periodic payments from an IRA for a defined minimum period — remains an available option that SECURE Act 2.0 did not eliminate. This strategy is particularly relevant for early retirees in the 50-to-62 age range who are drawing down IRA balances before Social Security and Medicare eligibility arrive. Our resource on what is a 72(t) distribution covers the mechanics, calculation methods, and compliance requirements for this approach, including how SECURE 2.0’s penalty reduction for missed RMDs interacts with the 72(t) framework.

529-to-Roth IRA Rollovers — Resolving the Overfunded Education Account Problem

One of the more creative provisions in SECURE Act 2.0 is the ability, effective in 2024, to roll over unused funds from a 529 college savings account into a Roth IRA for the 529 beneficiary. This provision addresses the long-standing planning problem of 529 accounts that have been overfunded relative to actual education costs — either because a child received scholarships, changed educational plans, or simply didn’t spend all the funds in the account. Before SECURE 2.0, the options for unused 529 funds were limited to using them for qualified education expenses, paying taxes and penalties on non-qualified withdrawals, or transferring to another family member’s 529. The new rollover provision allows the 529 beneficiary to receive up to $35,000 in lifetime rollovers (subject to annual Roth contribution limits), provided the 529 account has been open for at least 15 years. This is a meaningful estate planning and retirement savings tool for families who have been disciplined 529 investors and now find themselves with more education savings than expected education expenses.

Annuities Under SECURE Act 2.0 — How Guaranteed Income Fits Into the New Framework

Annuities play a strategically important role in retirement income planning under SECURE Act 2.0 for several interconnected reasons. The extension of the pre-RMD window creates more years during which a retiree needs to generate income from portfolio assets or guaranteed income vehicles rather than from mandatory IRA distributions. The uncertainty around future marginal tax rates — particularly given the expanded Roth provisions and the eventual sunset of existing individual tax rate schedules — makes guaranteed income streams that are not subject to market volatility increasingly valuable as a planning anchor. And the increasing IRMAA and Social Security taxation thresholds that are sensitive to adjusted gross income make income sources whose tax treatment is predictable and controllable particularly attractive.

Qualified Longevity Annuity Contracts (QLACs) received a meaningful enhancement under SECURE Act 2.0: the law removed the prior restriction limiting QLAC purchases to 25% of the IRA balance and replaced it with a flat dollar maximum (indexed for inflation). This allows retirees with larger IRA balances to purchase more meaningful QLAC coverage — setting aside a defined portion of their IRA in a deferred income annuity that begins payments at a specified advanced age (typically 80 or 85), reducing the RMD obligation in earlier years and providing guaranteed income protection against longevity risk later in retirement. Our resource on what is a QLAC covers how these contracts work within IRAs and how they interact with the RMD framework under the current rules. For the broader question of whether annuity income can satisfy RMD requirements, our guide on does annuitization satisfy RMDs covers the mechanics of how annuity payout structures interact with RMD obligations — a critical planning question for retirees considering annuitization of qualified assets. Our overview of how to use an annuity in retirement covers the full range of annuity strategies available within the post-SECURE 2.0 planning environment.

The Inherited IRA Ten-Year Rule — What SECURE 2.0 Did Not Change

One important clarification for families engaged in estate and beneficiary planning: SECURE Act 2.0 did not change or modify the inherited IRA ten-year rule that was introduced by the original SECURE Act of 2019. Most non-spouse beneficiaries of traditional IRA accounts inherited after January 1, 2020 must still fully distribute the inherited account within ten years of the original owner’s death, with annual distribution requirements during that window when the original owner died after their Required Beginning Date. SECURE 2.0 added the provision that annual distributions for affected beneficiaries in 2021-2024 would not be penalized, but the underlying ten-year structure remained intact, and full enforcement began with the 2025 tax year. Our dedicated resource on the stretch IRA ten-year rule covers the complete inherited IRA distribution framework, including the annual RMD requirement for post-RBD deaths and the tax management strategies available within the ten-year window. For the specific treatment of inherited annuities — which have their own distribution rules that differ from IRA treatment — our guides on inherited qualified annuities and inherited non-qualified annuities cover the relevant tax logic for each account type. The annuity beneficiary and death benefits resource covers how annuity death benefit provisions interact with estate planning more broadly.

SECURE Act 2.0

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FAQs: SECURE Act 2.0

What is SECURE Act 2.0 and when did it take effect?

SECURE Act 2.0 — formally the Consolidated Appropriations Act of 2023 — was signed into law on December 29, 2022. It contains more than 90 provisions affecting retirement savings accounts, required minimum distributions, Roth contributions, inherited accounts, and employer-sponsored retirement plans. Its provisions have rolled out across multiple years: the most significant changes began in 2023 (higher RMD age, lower RMD penalty), continued in 2024 (Roth 401k RMD exemption, student loan matching, 529-to-Roth rollovers), expanded in 2025 (super catch-up contributions, automatic enrollment for new plans), and continue into 2026 (mandatory Roth catch-ups for high earners) and 2027 (Saver’s Match). Tax laws are subject to change; readers should verify current rules with a tax professional.

What is the new required minimum distribution age under SECURE Act 2.0?

SECURE Act 2.0 increased the RMD starting age to 73 for individuals born between 1951 and 1959, effective January 1, 2023. For individuals born in 1960 or later, the RMD age will increase further to 75 beginning in 2033. Those who had already turned 72 before 2023 and were already taking RMDs continue under their existing schedule — the age change does not allow anyone to stop distributions already in progress. The extension of the RMD starting age creates a planning window for Roth conversions, bracket-topping distributions, and income management strategies before mandatory withdrawals begin — but requires deliberate use to avoid building a larger pre-tax balance that produces larger mandatory distributions later.

Are Roth 401(k) accounts now exempt from required minimum distributions?

Yes — effective January 1, 2024, Roth accounts in employer retirement plans (Roth 401(k) and Roth 403(b) accounts) are no longer subject to required minimum distributions during the account owner’s lifetime, aligning them with the treatment of Roth IRAs. Before this change, Roth 401(k) account holders had to either take RMDs from those accounts or roll them into Roth IRAs before RMDs began. That requirement no longer exists. Roth employer plan balances can now remain in the plan growing tax-free without any mandatory distribution obligation during the owner’s lifetime, though beneficiaries of these accounts remain subject to the inherited account distribution rules.

What are the super catch-up contributions for workers ages 60–63?

Starting January 1, 2025, workers who are ages 60, 61, 62, or 63 during the calendar year can make “super catch-up” contributions to eligible employer retirement plans equal to the greater of $10,000 or 150% of the regular catch-up contribution limit (both amounts are indexed for inflation). For 2025, the super catch-up limit was $11,250 — substantially higher than the $8,000 standard catch-up available to workers 50 and older. This provision creates the largest last-minute retirement savings opportunity in the tax code’s history for workers in this specific age window who want to maximize retirement account balances before leaving the workforce. Workers should confirm their plan has been amended to support this contribution before updating their deferral elections.

What is the mandatory Roth catch-up requirement for high earners starting in 2026?

Starting January 1, 2026, employees age 50 or older who earned more than $145,000 (indexed for inflation from the prior year’s FICA wages) must designate all catch-up contributions to employer retirement plans as Roth (after-tax) contributions rather than pre-tax. This applies regardless of the employee’s preference for pre-tax or Roth treatment. Employers whose plans do not offer a Roth contribution option must add one before 2026 or be unable to accept catch-up contributions from affected high earners. The IRS issued final regulations in September 2025 establishing a good-faith compliance period throughout 2026 as plans implement the required administrative changes. This provision will effectively require most retirement plans that allow catch-up contributions to add Roth capability.

Does SECURE Act 2.0 change the inherited IRA ten-year rule?

No — SECURE Act 2.0 did not change or modify the inherited IRA ten-year rule established by the original SECURE Act of 2019. Most non-spouse beneficiaries of traditional IRA accounts inherited after January 1, 2020 must still fully distribute the inherited account within ten years of the original owner’s death. SECURE 2.0 did not extend, modify, or replace this rule. The IRS waived penalties for missed annual distributions within the ten-year window for 2021–2024 while finalizing regulations, but that grace period ended after 2024. Full enforcement of annual distribution requirements (when applicable) began with the 2025 tax year. Beneficiaries and their advisors should consult our dedicated stretch IRA ten-year rule resource for the complete framework.

How do annuities fit into SECURE Act 2.0 retirement planning?

Annuities play an increasingly strategic role in SECURE Act 2.0 planning across several dimensions. Guaranteed income from annuities can stabilize retirement cash flow during the pre-RMD window, reducing the need to liquidate volatile assets for income. QLAC contracts within IRAs — which received expanded contribution limits under SECURE 2.0 — can defer mandatory distributions from a portion of the IRA balance to age 80 or 85, reducing RMD obligations in earlier years and providing guaranteed longevity protection. Annuities that satisfy RMD requirements through their payout structures can simplify distribution compliance for qualified assets. And guaranteed income sources that don’t vary with market performance make taxable income more predictable and controllable — a significant advantage when managing IRMAA thresholds and Roth conversion brackets across the pre-RMD and early-RMD years.

What is the Saver’s Match and when does it start?

The Saver’s Match is a SECURE Act 2.0 provision that will replace the existing Saver’s Tax Credit starting in 2027. Unlike the Saver’s Credit — which reduces tax liability on a return but has limited value for lower-income workers who owe little tax — the Saver’s Match provides a direct federal matching contribution of up to $1,000 per individual deposited directly into a qualifying retirement account. This transforms the incentive from a tax credit that may be partially wasted for lower-income savers into an actual retirement asset that benefits from tax-deferred growth. The Saver’s Match is designed to incentivize retirement savings among lower- and middle-income workers by providing a direct financial benefit rather than a paper tax reduction.

About the Author:

Jason Stolz, CLTC, CRPC, DIA, CAA and Chief Underwriter at Diversified Insurance Brokers (NPN 20471358), is a senior insurance and retirement professional with more than 25 years of real-world experience helping individuals, families, and business owners protect their income, assets, and long-term financial stability. As a long-time partner of the nationally licensed independent agency Diversified Insurance Brokers, Jason provides trusted guidance across multiple specialties—including fixed and indexed annuities, long-term care planning, personal and business disability insurance, life insurance solutions, Group Health, Travel Medical and Evacuation Insurance, and short-term health coverage. Diversified Insurance Brokers maintains active contracts with over 100 highly rated insurance carriers, ensuring clients have access to a broad and competitive marketplace.

His practical, education-first approach has earned recognition in publications such as VoyageATL, as well as his agency's featured coverage in Kiplinger— highlighting his commitment to financial clarity and client-focused planning. Drawing on deep product knowledge and years of hands-on field experience, Jason helps clients evaluate carriers, compare strategies, and build retirement and protection plans that are both secure and cost-efficient. Visitors who want to explore current annuity rates and compare options across multiple insurers can also use this annuity quote and comparison tool.

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