12/31/2025
2026 RETIREMENT CHANGES
Effective January 1, 2026, SECURE 2.0 requires any Highly Paid Individual (HPI) to contribute their Catch-up contributions as Roth deferrals.
Who is affected by the Roth Mandate?
Participants in a 401(k), 403(b) or governmental 457(b) plan who:
Are age 50 or older during the calendar year, and
Earned more than $150,000 (indexed for inflation) in F**A wages (Box 3 of Form W-2) in the previous year from an employer sponsoring the plan. These participants are known as Highly Paid Individuals (HPI). Note, if an employee does not have F**A wages (e.g., K-1 income earners) they are not subject to the Roth mandate.
Plans with a Roth provision:
Plans that offer a Roth option must ensure catch-up contributions for participants subject to the Roth mandate are designated as Roth deferrals.
Plans without a Roth provision
There is no requirement to add a qualified Roth feature. However, contributions for catch-up eligible participants subject to the Roth mandate will be limited to the standard IRS contribution limit, with no catch-up contributions permitted.
The Roth catch-up mandate represents a significant change for plan sponsors and participants. Employers should prepare for these changes by:
Ensuring their plans allow Roth contributions if they intend to allow all participants to have the opportunity make up catch-up contributions.
Working with their payroll provider to ensure the payroll provider is ready to monitor the applicable limits and whether they will administer the Roth mandate.
Communicating the Roth mandate to affected Highly Paid Individuals.
Coordinating with the plan’s recordkeeper, and the third-party administrator, if applicable.
Finally, the Roth mandate will require coordination between plan sponsors, recordkeepers, third party administrators (TPAs), and payroll providers. Plan sponsors should work with their payroll provider to ensure catch-up contributions are managed correctly by changing affected participants (HPIs) catch-up contributions to Roth or stopping them, as appropriate.
Annual Limits for 2026:
Maximum Deferral Contribution Limit is $24,500
Catch-up Contribution Limit is $8,000 (age 50 or older are eligible) or $11,250 (ages 60-63)*
*Note, SECURE 2.0 provides an increased Catch-up Contribution limit that applies to employees who attain ages 60, 61, 62 and 63 during 2026. However, this increase is not available for the year the employee turns 64. This higher catch-up limit increased to $11,250 from $8,000.