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Starting January 1, 2026, if you are 50 or older and earned more than $150,000 in FICA wages from your employer last year, your 401(k) catch-up contributions must be made as Roth (after-tax) instead of pre-tax. The rule applies only to workplace plans, only to the catch-up portion, and not to IRAs.
A SECURE 2.0 change takes effect in 2026 that quietly reshapes catch-up contributions for higher earners. If it applies to you, the extra catch-up money you put in your 401(k) can no longer be pre-tax; it has to go into the Roth side of the plan. Here is exactly who it affects, what changes, and how to plan around it. For the full picture of 2026 limits, see our 2026 contribution limits guide and the retirement accounts hub.
- The rule applies if you are 50+ and your prior-year FICA (Social Security) wages from that employer were more than $150,000 (a threshold indexed from $145,000).
- It affects only the catch-up portion of workplace plans (401(k), 403(b), governmental 457(b)), which for 2026 is $8,000, or $11,250 at ages 60 to 63. Your regular contributions are unaffected.
- Affected catch-up dollars must go to the Roth (after-tax) side, so you lose the upfront deduction on that slice but gain tax-free growth and withdrawals.
- IRAs are not affected, and the test is based on FICA wages from one employer, so a new job with no prior-year wages there, or income without FICA wages, can fall outside it.
- If your plan does not offer a Roth option, affected high earners may not be able to make catch-up contributions at all until the plan adds one.
What is the new Roth catch-up rule?
Under Section 603 of the SECURE 2.0 Act, higher earners age 50 and over can no longer make pre-tax catch-up contributions to a workplace retirement plan. Those catch-up dollars must instead go into the Roth portion of the plan, where you pay tax now and withdraw tax-free later. The change takes effect for catch-up contributions on or after January 1, 2026. The IRS released final regulations on September 15, 2025, with formal enforcement applying to plan years after December 31, 2026 and a good-faith compliance expectation in 2026.
Regular elective contributions, up to the standard $24,500 limit for 2026, are not affected. Only the catch-up amount changes, and only for people above the income threshold.
Who does the rule apply to?
Two conditions both have to be true:
- You are 50 or older (by the end of the year), making you eligible for catch-up contributions in the first place.
- Your prior-year FICA wages from that employer were over $150,000. This is the Social Security wage figure (Box 3 of your W-2), indexed from the law’s $145,000 base, and it looks at the previous calendar year.
Because the test is based on FICA wages from a single employer, a few situations fall outside it: a worker who changed employers and has no prior-year wages from the new one, and income that is not FICA wages (such as pure self-employment income, which is subject to self-employment tax rather than FICA withholding). If you are below the $150,000 threshold, you can still choose pre-tax or Roth catch-up as before.
How much is the 2026 catch-up?
| Age (2026) | Catch-up amount | Total 401(k) limit |
|---|---|---|
| Under 50 | None | $24,500 |
| 50 to 59 | $8,000 | $32,500 |
| 60 to 63 (super catch-up) | $11,250 | $35,750 |
| 64+ | $8,000 | $32,500 |
For an affected high earner, that $8,000 (or $11,250 at ages 60 to 63) is the part that now must be Roth. The larger ages 60 to 63 super catch-up has its own guide.
Is the Roth requirement good or bad for you?
It is a trade-off, not strictly a loss. With pre-tax catch-up, you got a deduction now and paid tax at withdrawal. With Roth catch-up, you pay tax now and withdraw tax-free, with no required minimum distributions on the Roth side. For someone who expects similar or higher tax rates in retirement, locking in today’s rate can be an advantage; for someone in their peak earning years who expects a much lower bracket later, losing the upfront deduction on that slice is a mild downside.
The practical reality: it applies only to the catch-up portion, so the dollar impact is modest relative to your full contribution. The framework for weighing tax-now versus tax-later is the same one in our Traditional vs Roth guide.
What should you do to prepare?
- Check your W-2 Box 3 (Social Security wages) from last year to see if you are over $150,000 with that employer.
- Confirm your plan offers a Roth option. If it does not, affected high earners may be unable to make catch-up contributions until it is added, so ask HR.
- Update your contribution elections so the catch-up portion is directed to Roth if you are affected. Many plans handle this automatically, but verify.
- Plan for the tax bill. Roth catch-up means no deduction on that slice, so your taxable income is slightly higher than under the old pre-tax approach.
Frequently Asked Questions
It applies to catch-up contributions made on or after January 1, 2026. The IRS issued final regulations on September 15, 2025; formal enforcement applies to plan years beginning after December 31, 2026, with a good-faith compliance expectation in 2026.
If your FICA (Social Security) wages from that employer in the prior year were more than $150,000, your catch-up contributions must be Roth. The threshold is indexed from the law’s $145,000 base. It is based on FICA wages from one employer, not your total household income.
No. It applies only to the catch-up portion of workplace plans (401(k), 403(b), governmental 457(b)). Your regular elective contributions up to $24,500 and your IRA contributions are unaffected.
Then affected high earners may not be able to make catch-up contributions at all until the plan adds a Roth option. Many employers have added one in response to this rule, so check with HR if you are 50+ and over the income threshold.
The test is based on FICA wages from an employer. Pure self-employment income is subject to self-employment tax rather than FICA wage withholding, so it generally is not counted the same way, though the details depend on your plan and structure. Confirm with a tax professional for your situation.
The bottom line
If you are 50+ and earned over $150,000 in FICA wages from your employer last year, your 2026 catch-up contributions must be Roth. It changes only the catch-up slice, not your regular contributions or your IRA, and it trades an upfront deduction for tax-free growth on that money.
- See all the 2026 numbers: our 2026 contribution limits guide.
- Ages 60 to 63? Read about the super catch-up worth up to $11,250.
- Weighing Roth vs pre-tax? Read our Traditional vs Roth guide and how to maximize your 401(k).
A quick note: this article is for educational purposes only and is not financial or tax advice. The rule and its thresholds come from the IRS and SECURE 2.0 and apply to 2026; verify current figures at IRS.gov and consult a qualified tax professional or your plan administrator about your situation.
