For obvious reasons, whatever I say here is NOT set in stone as we have not yet released anything. However, our current approach is to provide separate elements for Roth catch-up processing for 401k/403b/457 plans. And we are not planning on providing any "upgrade" option; you will need to re-implement your deferred comp plans in order to have those deferred comp plans be compliant with SECURE Act 2.0 requirements.

When we release our changes, we will ensure this is clearly documented.

Currently, the Roth 401k and Roth 457 do not have separate catchup elements. If Oracle creates a separate catchup element for the Secure Act 2.0 to handle the Roth portion of the regular 401k catchup, will we need to reimplement our Roth 401k and Roth 457 setup? Or will Oracle be able to update the setup with a patch?

Asking because we've had a request to implement a Roth 457 this year, and we do not want to do this if we're just going to have to reimplement again for the 2026 deadline.