What’s Changing and Why It Matters
Under the SECURE 2.0 Act (a retirement savings law enacted in 2022 with provisions now being implemented), a new rule affects how certain older, higher-paid workers make catch-up contributions to workplace retirement plans such as 401k, 403b, and governmental 457b plans.
Broadly:
The Key Change
Beginning in 2026, if an employee:
then any catch-up contributions they make must be designated as Roth contributions (i.e., after-tax). If the plan does not offer a Roth option, those individuals cannot make catch-up contributions. This applies to catch-up contributions beginning in 2026.
Client FAQ: Catch-Up Contributions Under SECURE 2.0
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What exactly is changing starting in 2026?
Anyone age 50 or older who earned above the IRS wage threshold in the prior year must make all catch-up contributions on a Roth (after-tax) basis instead of the traditional pre-tax way.
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Who is considered a “higher earner” for this rule?
A “higher earner” is someone who exceeded the threshold for Social Security wages from their employer in the prior year. For 2026 planning, that threshold is $145,000.
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Why does this matter for me or my retirement plan?
Making catch-up contributions as Roth means you pay tax on the contribution today rather than later in retirement, reducing your current-year tax deduction on that amount. It can still grow tax-free and be drawn tax-free in retirement.
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What if my employer’s plan doesn’t offer Roth contributions?
If your plan doesn’t offer a Roth contribution option and you are subject to the mandatory rule, you may not be able to make any catch-up contributions. Most plans now offer Roth options, but it’s critical to confirm.
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Can I still make traditional catch-up contributions if I earn less than the threshold?
Yes. If your prior-year wages are below the threshold, you can still choose traditional (pre-tax) or Roth catch-up contributions if your plan allows both.
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Does this affect the standard contribution limit too?
No. This only changes the catch-up portion for higher earners. The standard annual contribution limits and age-based “super catch-up” amounts (e.g., higher limits for ages 60-63) are separate and still apply. See 2026 limits in our Year-End Tax Planning Guide.
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What should I do now to prepare?
Check whether your employer’s plan offers a Roth contribution option, and work with your tax and retirement advisors to evaluate whether Roth catch-up contributions make sense for your tax and retirement goals given this new rule.