Updated July 28, 2026. Quick answer: It applies now. The IRS transition relief in Notice 2023-62 ran only “until taxable years beginning after December 31, 2025” and has expired. The final regulations apply from 2027, but that is the regulations’ applicability date — the statutory requirement itself is in force, under a reasonable good-faith standard. Guidance telling you this is “delayed to 2027” is conflating the two.
Three dates, and only one of them is the answer
| Date | What it actually is |
|---|---|
| Taxable years after 31 Dec 2023 | The statutory effective date in SECURE 2.0 §603(c) |
| 31 Dec 2025 | End of the administrative transition period in Notice 2023-62. This is the date that matters. |
| Taxable years after 31 Dec 2026 | When the final regulations (T.D. 10033) begin to apply — not when the requirement begins |
Notice 2023-62 said that during the transition period catch-up contributions would be “treated as satisfying the requirements of section 414(v)(7)(A), even if the contributions are not designated as Roth contributions.” The final regulations state that they “do not extend or modify the administrative transition period” and that for earlier years “a reasonable, good faith interpretation standard applies.”
So the requirement is live and the regulations simply have not caught up to it yet. A plan relying on “it starts in 2027” is relying on the wrong date.
Whether it reaches you turns on FICA wages, not income
IRC §414(v)(7)(A) is triggered by “wages (as defined in section 3121(a)) for the preceding calendar year from the employer sponsoring the plan.” Three things follow, and each is commonly got wrong:
| It is | It is not |
|---|---|
| FICA wages under §3121(a) | W-2 box 1, total compensation, or AGI |
| The preceding calendar year | The current year |
| From the plan-sponsoring employer only | Your total income from all sources |
Which means a large group of business owners is not caught at all. An owner with no FICA wages from the sponsoring employer — a sole proprietor or a partner — falls outside the rule entirely, at any income level. An S-corp owner-employee does have FICA wages and can be caught by it.
Every dollar limit in this area is indexed and changes annually. The figures printed in the Code itself — $40,000 for the defined-contribution limit, $160,000 for the defined-benefit limit, $15,000 for elective deferrals — are 2001 and 2005 base amounts that will never be updated in the statute; IRC §415(d) and §402(g)(4) do the adjusting. Get the current year’s figures from the IRS cost-of-living notice for that year rather than from any article, including this one. Nothing on this page states a dollar amount for that reason.
Sources
IRC §414(v)(1), (v)(2)(B), (v)(2)(C), (v)(2)(E) and (v)(3); §414(v)(7) (the Roth catch-up requirement) and (v)(7)(E) (its indexing); §402(g)(1) and (g)(4); IRS Notice 2023-62 (the administrative transition period); T.D. 10033, final regulations, Internal Revenue Bulletin 2025-40. All read July 2026.
This states what the cited authority says. It is not tax advice, and retirement-plan design turns on facts about your business and your other entities that no page can see. Every dollar limit referenced here is indexed and changes annually.