Mandatory Roth Catch-up
Mandatory Roth Catch-Up Contributions Begin in 2026
High earners will lose pre‑tax 401(k) catch‑up contributions and must make Roth contributions instead. Here's what you need to know before your paycheck potentially shrinks starting in 2026.
For nearly a quarter century, employers have offered their retirement savings plan participants age 50 and older a valuable opportunity: the chance to make additional catch-up contributions to their plans.¹
Thanks to the SECURE 2.0 Act passed in 2022, that opportunity became even more valuable: Employers may now allow plan participants aged 60 to 63 to contribute more than their other catch-up-eligible peers through “super catch-ups.”
In 2025, the standard plan contribution limit was $23,500. Participants ages 50 to 59 and 64 and older in 2025 can contribute an additional $7,500, while those ages 60 to 63 can contribute an additional $11,250.
However, SECURE 2.0 also included a provision requiring catch-up contributions to be made on a Roth basis for certain high-earning employees. In September 2025, the IRS issued final regulations on these mandatory Roth catch-ups, which will take effect this year.
The Big Picture
In most work-based savings plans, employees can make catch-up contributions and contribute on both a pre-tax and a Roth after-tax basis.² While pre-tax contributions reduce the proportion of a participant’s paycheck that is subject to current income taxes, Roth contributions allow participants to potentially build a tax-free nest egg for the future. Withdrawals from Roth accounts made after the account owner reaches age 59½ are tax-free, provided the account has been held for at least five years; other exceptions apply.
Pre-tax contributions can be especially appealing to high earners, who may contribute as much as possible (up to plan limits) to maximize the opportunity to reduce current taxable income.
However, pre-tax contributions also reduce federal tax revenue. That may be why legislators included a provision in SECURE 2.0 requiring catch-up contributions for those earning more than $145,000 to be made on a Roth (post-tax), rather than a pre-tax basis. Initially slated to take effect in 2024, that provision was delayed until 2026 to allow the IRS to finalize rules and employers to modify their systems and plan documentation accordingly.³
The Details
In September 2025, the IRS issued final regulations stating that the new requirements generally apply to contributions in taxable years beginning after December 31, 2026. The IRS further stated, “The final regulations also permit plans to implement the Roth catch-up requirement for taxable years beginning before 2027 using a reasonable, good faith interpretation of statutory provisions.”⁴ Many industry observers interpret this language to mean that employers will be expected to begin implementing the new provisions in 2026.⁵ ⁷
To determine whether an employee exceeds the $145,000 threshold, employers will use Federal Insurance Contributions Act (FICA) wages listed in box 3 of the employee’s W-2 form from the previous year. In other words, to comply in 2026, employers will use 2025 W-2 forms. The rule does not apply to those who do not have prior-year W-2 wages, such as the self-employed.⁶ ⁸
The new rule applies to standard and super catch-ups in 401(k), 403(b), and 457(b) plans; however, the new Roth mandate does not apply to SIMPLE plans or the special catch-up contributions permitted in 403(b) and 457(b) plans. Plans that do not offer Roth contributions must either add a Roth feature or disallow high earners from making catch-up contributions.⁷ ⁹ ¹¹
Tax and Retirement-Savings Impacts
High earners who may be subject to the new rule might want to review their tax-planning and retirement-savings strategies soon. Although Roth contributions can provide substantial tax benefits in the future, eliminating the pre-tax catch-up contribution could have a surprising impact on income tax planning during the 2026 tax-filing season.
Richard Siminou is a financial advisor and founder of Siminou Wealth Management, a fee-only investment advisory and financial planning firm based in New York serving clients nationwide.
If you would like to review your current investment portfolio or discuss retirement, college, tax, or other financial planning considerations, you are welcome to contact us or visit https://siminouwm.com/
Siminou Wealth Management operates under a fiduciary standard and does not sell proprietary products. Initial consultations are complimentary for prospective clients.
Each client’s financial plan and investment objectives are developed based on their individual circumstances.
This content is for informational purposes only and does not constitute investment advice.
1) CNBC, January 4, 2017
2) PLANADVISER, October 1, 2025
3) IRS Notice 2023-62
4) IRS, September 15, 2025
5) Society for Human Resource Management, accessed October 2, 2025
6, 8) Plan Sponsor Council of America, September 30, 2025
7, 9, 10) Slott Report, September 22, 2025
11) ADP SPARK blog, accessed October 2, 2025
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