The 2026 Roth Catch-Up Rule: High Earners’ Catch-Up Contributions Must Be Roth

Starting with 2026 contributions, if your FICA wages from your employer exceeded $150,000 in 2025, every 401(k) catch-up contribution you make must be Roth (SECURE 2.0 §603). Payroll applies the switch automatically. At or below $150,000, you can still choose pre-tax catch-ups. If a plan has no Roth source, affected earners cannot make catch-ups at all.

By the About401K editorial team · Facts verified against IRS Notice 2025-67 and SECURE 2.0 §603 · Updated September 25, 2026

Am I subject to the Roth catch-up rule in 2026?

If you have just noticed a new Roth line on your pay stub and nobody warned you, this is almost certainly why. Run three checks, and all three have to be true before the mandate touches you.

1. You’re catch-up eligible: age 50 or older at any point in 2026, and making catch-up contributions above the $24,500 deferral limit.
2. Your 2025 FICA wages from the employer sponsoring the plan exceeded $150,000. These are prior-year wages, from that employer only. Wages from a different employer, self-employment income, and investment income don’t count toward this employer’s test.
3. You’re actually contributing catch-up dollars. The rule touches only the catch-up layer. Your first $24,500 of deferrals for 2026 can stay pre-tax regardless of income.

Two clean exemptions fall out of that wage test, and both come up constantly. The first is new hires. If you joined your employer in 2026, you have no 2025 FICA wages from that employer, so the mandate doesn’t apply to you there for 2026 even if you earned far more than $150,000 somewhere else.

The second is self-employed owners and partners. The test looks at FICA wages, and self-employment earnings are not wages, so a partner or sole proprietor who takes no W-2 from the business sits outside the mandate even at a very high income.

The deemed Roth election

You don’t file anything, and in most plans you never make a choice at all. Once your regular deferrals cross $24,500 and dollars start classifying as catch-up, payroll checks your prior-year wage flag. If you are over the threshold, it designates those catch-up dollars as Roth automatically.

The IRS regulations under §414(v)(7) bless this arrangement as a “deemed Roth election.” By electing catch-up contributions at all, an affected participant is treated as having elected Roth treatment for them, with the ability to change or stop the election going forward.

Your pay stub, not a form, is where you will actually see it happen. After the crossover point, the catch-up portion shows up as Roth and your withholding rises accordingly. If that surprises you in September, this is the explanation.

Plans that use “spillover” administration, where deferrals automatically reclassify as catch-up after $24,500, handle all of this invisibly. Plans with a separate catch-up election may simply present Roth as the only catch-up option for flagged participants.

Plans without a Roth option

If a plan lacks a Roth option entirely, affected high earners get no catch-up at all. That is not a typo, and there is no pre-tax fallback anywhere in the statute. A plan without a designated Roth source cannot accept any catch-up contributions from participants over the wage threshold.

This is why recordkeepers spent 2024 and 2025 pushing the remaining holdout plans to add a Roth 401(k) feature. If your plan still lacks one, every year costs you $8,000 of contribution room, or $11,250 during the ages 60–63 window. That is worth raising with HR now rather than next December, because adding a Roth source is a plan amendment and it takes time.

Participants at or below the threshold keep their pre-tax catch-ups either way, so this problem is confined to the high-wage group.

Effective-date history

The path from enactment to enforcement took three years, and the delays are the reason so many people are meeting this rule for the first time now.

• December 2022: SECURE 2.0 enacted. Section 603 requires Roth treatment for catch-ups by high earners, with a statutory effective date of taxable years beginning after December 31, 2023, i.e., 2024. (The section also contained a famous drafting error that technically deleted the authorization for any catch-up contributions; the IRS confirmed catch-ups would continue while Congress and Treasury sorted the text.)
• August 2023: With payroll systems nowhere near ready, IRS Notice 2023-62 announced a two-year “administrative transition period.” For 2024 and 2025, catch-ups could stay pre-tax for everyone without penalty.
• 2025: The IRS issued final regulations under §414(v)(7), settling the mechanics: the deemed Roth election, the per-employer FICA-wage test, and plan-administration rules.
• January 2026: The transition is over. The mandate applies to catch-up contributions made in 2026, tested against 2025 wages (IRS Notice 2025-67 confirms the $150,000 threshold).

The real tax cost

It helps to be precise about what actually changed here, because the rule sounds worse than it is. This is a timing change, not a penalty. Pre-tax catch-ups gave you a deduction now and taxable withdrawals later. Roth catch-ups tax you now and pay out tax-free later. What the mandate really removes is your ability to choose which side of that trade you take.

FICA wages, not “compensation”: why the definitions matter

The $150,000 test uses wages as defined for FICA (Social Security) tax purposes. In practice, that is the Social Security wage figure your employer reported for 2025, and it is not the same number as the plan’s §415 compensation or your gross salary.

Deferrals don’t reduce FICA wages, but some items do, certain pre-tax benefits among them. That is why someone with a $152,000 salary can land under the threshold while a $148,000 earner with a large bonus lands over it. If you are anywhere near the line, look up the reported figure rather than guessing from your offer letter.

Don’t confuse this test with the HCE test, which is a different rule entirely. The HCE test uses a different figure ($160,000 of prior-year §415-style compensation for 2026 testing), serves a different purpose (nondiscrimination testing), and includes ownership rules the catch-up mandate lacks. You can be an HCE but under the Roth catch-up threshold, or over the catch-up threshold without ever hearing the term HCE. The two thresholds also index separately.

Impact on the super catch-up

The mandate applies to the super catch-up as well, which catches some people off guard. The $11,250 super catch-up for participants aged 60–63 (IRC §414(v)(2)(E)) is still a catch-up contribution, so every dollar of it falls under the Roth requirement.

In practice, a 61-year-old with 2025 wages over $150,000 makes the entire $11,250 as Roth in 2026, on top of a $24,500 regular deferral that can remain pre-tax. Both tiers are covered in full detail in our guide to the 2026 catch-up contribution limits.

Practical steps

Nothing is required of you. Payroll enforces the rule, and you cannot accidentally violate it. But three moves are worth thinking about.

• Revisit your Roth-versus-traditional split deliberately. The mandate forces Roth money into your account anyway. Some savers respond by making more of their regular $24,500 Roth too, building the tax-free bucket. Others keep the full $24,500 pre-tax to preserve every remaining deduction. The framework is here, on Roth vs. traditional.
• Check the withholding math. Losing the deduction on $8,000–$11,250 raises your 2026 tax bill by four figures at high brackets; adjust estimated payments or W-4 withholding if you cut it close.
• Know your five-year clock. If these are your first Roth 401(k) dollars, the mandate just started your plan’s five-year clock, which is a quiet benefit of being forced in early.

• ☐ Ask whether the plan has a designated Roth source. If it doesn’t, you lose your catch-up room entirely, so this is the first question and the most urgent one.
• ☐ Ask which wage figure they used to flag you. It should be your 2025 FICA wages from this employer, not your 2026 salary and not your total compensation.
• ☐ Tell them if you joined in 2026. A new hire has no prior-year wages from this employer, so the mandate shouldn’t apply to you here for 2026.
• ☐ Tell them if you take no W-2 from the business. Partners and sole proprietors with self-employment earnings instead of wages fall outside the test.
• ☐ Ask whether the plan uses spillover or a separate catch-up election. Spillover reclassifies your deferrals automatically after $24,500. A separate election means you may have a box to check.
• ☐ Ask where the Roth catch-up will appear on your pay stub. Knowing the line item name ahead of time saves a confused phone call in the fall.
• ☐ Ask them to confirm your election is prospective. You can change or stop catch-up contributions going forward, and payroll should be able to tell you the cutoff for each pay period.

Related reading

• 2026 catch-up contributions: the $8,000 and $11,250 limits
• Roth 401(k): how it works and when to choose it
• All 2026 401(k) contribution limits in one place

Sources: IRC §414(v) · IRS Notice 2023-62 (transition period) · IRS Notice 2025-67 (2026 limits) · IRS: catch-up contributions