IRS Releases Guidance on Student Loan Matching Contributions

The IRS has issued Notice 2024-63 (Notice) providing guidance under Section 110 of SECURE 2.0 regarding employer matching contributions with respect to qualified student loan payments (QSLP). The Notice addresses several matters in question-and-answer format, including the following.

• Overview of QSLP including definition, eligible plan types, and contribution and eligibility restrictions
• Employee certification requirements and timing
• Administrative procedures that can reasonably be implemented
• ADP test options under a single test or disaggregated basis
• Miscellaneous items such as applicability to SIMPLE IRA plans, timing of amendments and frequency of match, and corrections

This guidance is applicable for plan years beginning after December 31, 2024, but can be relied upon in the interim as a good faith reasonable interpretation of Section 110 of SECURE 2.0. Comments are being accepted for 60 days after publication in the Federal Register, and the IRS indicates they expect to issue proposed regulations. The Notice will be reviewed, and additional details provided as warranted.