Mike Hadley Featured in Planadviser.com Article on New IRS Guidance on Roth Catch-Up Contributions
- Published Date: September 19, 2025
Davis & Harman Partner, Mike Hadley, was recently featured in the Planadviser.com article, “How Employers Can Prep for New Rules on Roth Catch-Ups,” where he was cited as a legal expert discussing how employers need to implement the new Roth catch-up contribution mandate under SECURE 2.0.
The Planadviser.com article discussed the Treasury Department and Internal Revenue Service release of highly anticipated final regulations implementing the Roth catch-up contribution requirement under section 603 of SECURE 2.0. The final rules require highly compensated employees who elect to make age-based catch-up contributions do so on a Roth basis.
The final regulations clarify that the mandate will go into effect as scheduled, without a further delay in the effective date.
Mike Hadley is quoted in the article saying:
“This is not something that, in 2026, an employer can just ignore.”
Employers and plan sponsors who allow eligible employees to make age-based catch-up contributions must ensure that employees exceeding the wage threshold for the Roth catch-up mandate are electing to make said contributions on a Roth basis. The final rules allow for a reasonable, good faith interpretation of the regulations in 2026.
A link to the full article can be found here.
