Mandatory Roth catch-up contributions hit high earners in 2026

What changed SECURE 2.0's mandatory Roth catch-up rule is now operative for 401(k), 403(b) and governmental 457(b) plans. Employees age 50 or older whose prior-year Social Security wages from that same employer exceeded the indexed threshold (based on $145,000, indexed) can only make catch-up contributions as Roth contributions. Pre-tax catch-up is no longer available to them. Why it is an HR and payroll problem, not just a plan problem The determination is made off prior-year FICA wages from your organization only. That means payroll has to flag affected employees each January, feed the flag to the recordkeeper, and fail the pre-tax catch-up election gracefully. Plans that do not offer a Roth feature cannot allow catch-up contributions for affected employees at all. What HR needs to do - Confirm your plan document has been amended and that the recordkeeper and payroll system agree on who is flagged. - Add a Roth source to the plan if you do not have one. - Communicate to affected employees before the first payroll of the year — the tax surprise is real, and it lands on your most senior people. - Handle mid-year new hires carefully: prior-year wages from a previous employer do not count. - Document your correction procedure for deferrals that were mis-sourced. Also note The super catch-up for employees ages 60 through 63 remains available and interacts with this rule.