Mandatory Roth Catch-Up Contribution Rules for High Earners

Beginning in 2026, mandatory Roth catch-up contributions for high earners take full effect: if your FICA wages from the employer sponsoring your 401(k), 403(b), or governmental 457(b) exceeded $150,000 in 2025, every dollar of your age-50-and-over catch-up contribution must go into a Roth account rather than pre-tax.¹ You lose the current-year tax deduction on those dollars. In exchange, they grow and come out tax-free in retirement if the withdrawal is qualified.

Who Counts as a High Earner

The test is whether your FICA wages from the plan sponsor topped $150,000 during the prior calendar year. For 2026 contributions, that means 2025 wages. The statute originally set the threshold at $145,000, but it adjusts for inflation in $5,000 increments after 2024.²

Read “FICA wages” as the Social Security wages in Box 3 of your W-2, not Medicare wages in Box 5. Box 5 has no cap; Box 3 is subject to specific exclusions that may keep your number lower than you’d guess.³ If you earned $150,000 or less at the plan sponsor in 2025, you can still make pre-tax catch-up contributions the way you always have.

Multiple Employers

Wages from separate, unrelated employers are not stacked. The test looks only at what the employer sponsoring the plan paid you.³ If two of your employers share a common paymaster or belong to a related corporate group, the plan may aggregate their wages, but ordinary multi-employer situations do not.

New Hires

If you joined the company in 2025 and had no 2024 wages from that employer, the Roth catch-up requirement does not apply to you for 2026. The rule needs a full prior calendar year of wages from the plan sponsor to measure against.

Self-Employed and Partners

Self-employment income is not FICA wages from a plan-sponsoring employer. Partners taking only guaranteed payments and self-employment income, and sole proprietors contributing to a solo 401(k), fall outside the mandate regardless of income level.³ Pre-tax catch-up contributions remain available.

How the Roth Catch-Up Works in Practice

Any catch-up you make above the standard deferral limit must be designated Roth. You pay income tax on that money in the year of contribution, and qualified withdrawals later come out tax-free, including all growth.⁴

This isn’t a choice you can opt out of. You can’t split catch-up between pre-tax and Roth, and you can’t elect all pre-tax. Your regular deferrals up to the $24,500 limit are unaffected and can stay pre-tax if you prefer. Only the catch-up piece above that limit is forced into Roth.²

For the tax-free payoff, withdrawals need to be qualified. That generally means you’re at least 59½ and the Roth account has been open at least five years. If your plan is adding Roth for the first time to comply with the mandate, the five-year clock starts with your first Roth contribution.

2026 Contribution Limits

The standard catch-up limit for participants 50 and older is $8,000 in 2026, on top of the $24,500 regular deferral limit, for a total of $32,500.⁵

A separate SECURE 2.0 provision creates an enhanced catch-up for participants who turn 60, 61, 62, or 63 during the year. For 2026, that enhanced limit is $11,250, bringing the maximum total to $35,750.⁵ Both tiers are subject to the Roth mandate for high earners:

Ages 50–59 and 64+: $8,000 catch-up, all Roth if you’re over the income threshold.
Ages 60–63: $11,250 catch-up, all Roth if you’re over the income threshold.

Which Plans Are Covered

The mandate applies to 401(k) plans, 403(b) plans used by public schools, hospitals, and nonprofits, and governmental 457(b) plans for state and local government employees.

SARSEP and SIMPLE IRA plans are explicitly excluded.⁴ If you contribute to a 401(k) at one job and a SIMPLE IRA at another, only the 401(k) catch-up is subject to the Roth requirement.

What if Your Plan Has No Roth Option

A plan that offers catch-up contributions but has no Roth feature is not required to add one. The consequence lands on the participant instead: if you’re subject to the Roth mandate and your plan has no Roth account, your catch-up limit is $0.⁶ You cannot make catch-up contributions at all.

Participants below the income threshold in the same plan can keep making pre-tax catch-up as usual, and the plan doesn’t lose its qualified status. If you’re in this situation, ask your HR department whether a Roth option is being added. Most large plan providers already have one; smaller plans and some governmental 457(b) plans are the likeliest gaps.

If Your Employer Codes a Contribution Wrong

Payroll systems have to track prior-year wages, apply the threshold to the current year, and code catch-up amounts as Roth once your regular deferrals hit the standard limit. Errors happen. The IRS built two correction paths into the final regulations rather than disqualifying plans that miscode a contribution.³

If a catch-up contribution that should have been Roth was deposited pre-tax, the plan can move it (adjusted for gains or losses) to your Roth account and either report it as a Roth contribution on your W-2 (if the W-2 hasn’t been filed yet) or process it as an in-plan Roth rollover reported on Form 1099-R. The correction deadline generally runs through the end of the taxable year after the year the deferral was made.

Two situations excuse the plan from correcting. First, if the misclassified amount is $250 or less, no correction is required. Second, if the employer couldn’t determine until after the correction deadline that your prior-year wages exceeded $150,000, correction is waived.³

Roth Employer Matching as a Related Option

A separate SECURE 2.0 provision lets plans offer employees the choice to designate employer matching and nonelective contributions as Roth. This has been available since December 29, 2022, for plans that opt in.⁷

Unlike the catch-up rule, Roth matching is optional on both sides. If you’re already making forced Roth catch-up contributions, designating the employer match as Roth expands the tax-free bucket further. You’d owe tax on those matching dollars in the year they’re allocated, reported on Form 1099-R. Whether the trade makes sense depends on how far you are from retirement and your expected tax rate then.

1
Internal Revenue Service. Notice 2025-67
2
Office of the Law Revision Counsel. 26 USC 414 – Definitions and Special Rules
3
Internal Revenue Service. Internal Revenue Bulletin 2025-40
4
Internal Revenue Service. Notice 2023-62 – Mandatory Roth Catch-Up Contributions
5
Internal Revenue Service. 401(k) Limit Increases to $24,500 for 2026, IRA Limit Increases to $7,500
6
Federal Register. Catch-Up Contributions
7
Internal Revenue Service. SECURE 2.0 Act Changes Affect How Businesses Complete Forms W-2