What Important Issues Should I Consider Regarding Changes Made by the SECURE Act 2.0?
What Important Issues Should I Consider Regarding Changes Made by the SECURE Act 2.0?
SECURE Act 2.0 introduced dozens of changes to retirement planning rules across multiple years. From raised RMD ages and expanded catch-up contributions to new emergency savings accounts and 529-to-Roth rollovers, understanding which provisions affect your plan—and when they went into effect—is essential for maximizing your retirement strategy.
Effective 2023: Key Changes
- RMD age changes: Born 1951–1959? Your RMD begins at age 73. Born 1960 or later? Your RMD begins at age 75. Plan Roth conversions and other strategies before RMDs commence to reduce long-term tax liability.
- QLAC limit raised: You can now put up to $210,000 (lifetime, inflation-adjusted) of your IRA into a qualified longevity annuity contract (QLAC) to delay RMDs on that portion until age 85.
- Roth employer matching: Employers may now offer matching contributions to Roth accounts (taxable to employee when received). Evaluate whether this aligns with your tax planning goals.
- Roth SEP and SIMPLE IRAs: Newly allowed. Consider whether Roth contributions make sense for your tax situation.
- Public safety worker early access: Qualified public safety workers (including private sector firefighters and state/local correctional officers) over age 50 may access retirement funds penalty-free upon separation. Special rules apply for those under 50 with 25+ years of service.
- Terminal illness exception: Penalty-free early withdrawals available if expected to pass away within seven years (physician certification required).
- Hardship withdrawal self-certification: Self-certification now allowed (no documentation required) to expedite hardship withdrawals. Keep supporting evidence in case of audit.
- QCDs to CRTs and CGAs: QCDs can now be made to charitable remainder trusts (CRTs) or charitable gift annuities (CGAs), subject to limitations.
- 529-to-Roth rollover: Extra 529 funds can now be rolled to the beneficiary’s Roth IRA (if they have earned income). Annual limit: $7,500 ($8,600 if 50+), reduced by regular contributions. Lifetime limit: $35,000 per beneficiary.
- Surviving spouse election: If your younger spouse has a retirement plan they may predecease you with, consider whether electing to be treated “”as the deceased spouse”” would be beneficial for RMD timing.
- Roth 401(k)/403(b) — no RMDs: Roth workplace retirement accounts are now RMD-free during the owner’s lifetime. Update your distribution planning accordingly.
Effective 2024: Key Changes
- Emergency retirement withdrawals: Up to $1,000 penalty-free per year for emergency expenses. Must repay or wait three years before withdrawing again.
- Domestic abuse exception: Penalty-free access up to $10,500 or 50% of vested balance (whichever is less) via self-certification.
- Emergency Savings Account: Some employer plans now offer a linked emergency savings account with a $2,600 limit. Evaluate whether this supplements your emergency fund goals.
- Employer match on student loan payments: If permitted by your employer, student loan payments can now trigger an employer match to your retirement plan.
- New and modified business retirement plans: Review SECURE 2.0 changes before making decisions about Starter 401(k) plans, non-elective contributions to SIMPLE plans, or employee participation hours.
- Retroactive solo 401(k) for sole proprietors: Sole proprietors may now retroactively establish a 401(k) for the prior tax year (as an alternative to a SEP IRA) if established and funded before the personal tax filing deadline.
Effective 2025: Key Changes
- Enhanced catch-up contributions (ages 60–63): If you’re between 60 and 63, you may make increased catch-up contributions of $10,000 (or 150% of the prior year’s applicable catch-up limit) to your 401(k), or $5,000 to your SIMPLE plan.
- New 401(k)/403(b) plans auto-enrollment: All employees must be auto-enrolled in new 401(k) and 403(b) plans established after 2024 (with exceptions for small employers, churches, and government).
Effective 2026: Key Changes
- LTC insurance distributions from retirement plans: You may now take penalty-free distributions (lesser of 10% of vested balance or $2,600, inflation-adjusted) from your retirement plan to pay qualified LTC insurance premiums.
- ABLE account expansion: Expanded access for individuals whose disability occurred before age 46.
- Mandatory Roth catch-up contributions: If your wages exceed $150,000 (prior year) and you plan to make catch-up contributions, your plan sponsor may require mandatory Roth catch-up contributions (effective 2027 technically, but plan sponsors may implement now).
Download the SECURE Act 2.0 Planning Checklist
Get the complete checklist organized by effective date, covering all SECURE Act 2.0 provisions relevant to your retirement plan, RMDs, catch-up contributions, emergency savings, charitable giving, and estate planning. Work through it with your advisor to ensure your strategy reflects the latest rules.