What SECURE 2022 changes start with 2024?

Without considering any plan-document change (most of which can wait until 2025 or the later remedial-amendment time):

• For an individual-account retirement plan with a § 401(k) arrangement (with no auto-anything provision, and no need or intent to add any);
• allowing non-Roth and Roth elective deferrals, including age-based catch-up (with non-Roth not restrained for those who had wages more than $145,000 in the preceding year);
• immediate eligibility with no age, service, or other condition beyond employment;
• no matching contribution, and no nonelective contribution;
• distribution permitted on age 59½ or severance from employment;
• no involuntary distribution (except as IRC § 401(a)(9) requires);
• no risk of a coverage, nondiscrimination, or top-heavy failure; and
• with the calendar year as the employer’s tax year, all participants’ tax year, the plan year, and the IRC § 415 limitation year:

Which SECURE 2022 changes must the plan sponsor put in operation starting with 2024?

Which SECURE 2022 changes may the plan sponsor put in operation starting with 2024?

This list doesn't include items that were or could be effective before 1/1/2024 and likely is missing some.

These are rules to follow starting in 2024 that could be considered "must make" changes should they be needed:

• change in attribution of stock between parents and minor children.
• make retroactive discretionary amendments after plan year end and by the due date of the tax return to increase benefits.

The plan may put in:

• emergency in-service withdrawals up to $1000 with no 10% excise and opportunity to repay.
• withdrawals for victims of domestic abuse with no 10% excise tax up to the lesser of $10,000 or half the account, and opportunity to repay.
• eliminating RMDs from Roth.
• allowing in the RMD rules for the surviving spouse to be treated as the deceased employee.

The plan may add to its existing plan design:

• a match and add matching contributions on student loan repayments.
• involuntary distributions with a cash-out limit to $7000 from $5000.

If the need arose, the plan could:

• use separate top-heavy testing for non-excludable and excludable employees.

Given the plan design presented, the plan should not have to worry about LTPT employees. 

Given recent IRS guidance, non-Roth catch-ups are allowed for everyone (and given universal availability of catch-ups any restrictions on High Paids to Roth-only likely are not allowed).

Thank you!