SECURE 2.0 Section #603 - Roth Catch-Up Requirement
Starting January 1, 2026, a new rule under the SECURE 2.0 Act will impact how certain employees can make catch-up contributions to their retirement plans.
On December 29, 2022, The Setting Every Community Up for Retirement Act of 2022 (SECURE 2.0 Act) was signed into law by the White House. The retirement legislation includes significant changes that could help strengthen the retirement system and improve Americans’ financial readiness for retirement. One key change is Roth Catch-up.
What’s Changing?
If you’re turning age 50 or older in 2026 and your total 2025 FICA wages (Box 3 of your W-2) with your current employer were more than $150,000*, any catch-up contributions you make in 2026 must be made on a Roth basis.
What this means for you:
Starting in 2026, your retirement plan will treat catch-up contributions as Roth for participants whose 2025 FICA wages exceed $150,000*. This is considered a deemed Roth election under the Roth catch-up requirement. If your 2025 FICA wages were over $150,000*, any catch-up contributions over the applicable plan limit you make in 2026 must be made on a Roth basis. If your FICA wages were $150,000* or less, your catch-up contribution may be pretax or Roth, depending on your plan options.
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