Secure Act 2.0 Question

The secure act 2.0 allows plans to fund matching and nonelective contributions as Roth.

1. I believe the participant must be 100% vested to do this correct?

2. What about safe harbor matching and nonelective contributions. Can they be funded as Roth?

Thanks!

I believe all employer contributions that are 100% vested can be elected as ROTH which would include safe harbor contributions. I think the 100% vesting of employer ROTH is because the employee is paying the taxes on 100% of the contribution so the IRS doesn't want forfeitures of ROTH.

And while it's technically currently available, there is no IRS guidance that I am aware of on how the income is reported to the employee and what withholding rules may apply. So I'm not sure if anyone is currently doing this.