Section 603 of the SECURE 2.0 Act of 2022 (“Section 603”) implements changes to catch-up contributions and is applicable to employers who maintain a 401(k), 403(b), or 457(b) plan with participants who are age 50 and older and whose income from the prior year exceeded $145,000. Section 603 requires that catch-up contributions must be made as Roth contributions (i.e., after tax basis) for those earning more than $145,000. Originally, Section 603 was set to become effective starting in 2024. However, on August 25th, 2023, in response to many industry groups urging for an extension, the IRS released Notice 2023-62 (the “Notice”) granting a two-year delay in the effective date. This relief means employers don’t need to add Roth as an option to retirement plans for those earning $145,000 before 2026 to comply with Section 603. During the transition period, catch-up contributions can continue on a pre-tax or Roth basis (if plan terms permit Roth contributions) until 2026 regardless of a plan participant’s income.