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The 2026 Roth Catch-Up Rule Is Final: What High Earners (and Everyone Else) Should Do Now

  • HFF Staff Writer
  • 3 hours ago
  • 4 min read
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If you’re 50+ and make retirement “catch-up” contributions at work, a big change just became real. The IRS finalized regulations that, starting in 2026, will require many higher-income employees to make those catch-ups on a Roth (after-tax) basis rather than pre-tax (IRS, “Treasury/IRS Final Regulations,” Sept. 15, 2025; Federal Register, Sept. 16, 2025). In plain English: no upfront tax deduction on those extra dollars if you’re over the income threshold—though the tradeoff is tax-free growth and withdrawals later (MarketWatch, 2025).


Let’s unpack what changed, who’s affected, and smart moves to consider before the calendar flips.


What changed, exactly?


  • Mandatory Roth catch-ups for high earners (2026): If your prior-year W-2 wages from your current employer exceed $145,000 (indexed), any age-50+ catch-up contributions to 401(k)/403(b)/governmental 457(b) must be Roth starting in 2026 (IRS; Federal Register; The Tax Adviser, 2025).

  • The threshold is employer-specific: It’s based on wages from the employer sponsoring the plan (not total household income). That nuance matters if you changed jobs or have multiple employers (Nixon Peabody, 2025).

  • “Super catch-up” remains (ages 60–63): SECURE 2.0’s enhanced catch-up (150% of the standard catch-up) still exists—also Roth-only if you’re over the wage threshold (MarketWatch, 2025; The Tax Adviser, 2025).

  • Transition relief through 2025 stands: The IRS earlier granted a runway so plans could adapt; the Roth-only rule bites starting January 1, 2026 (IRS Notice 2023-62; IRS update July 3, 2025).

  • If your plan lacks a Roth feature: You may not be able to make catch-ups at all in 2026 until your employer adds Roth (Investopedia, 2025).


Who is affected?


  • Age 50+ employees whose prior-year W-2 wages from the same employer exceed $145,000 (indexed) are in the Roth-only bucket (IRS; The Tax Adviser, 2025).

  • Self-employed folks without W-2 wages from an employer sponsoring the plan aren’t caught by this wage test in the same way (IRA Help, 2025).

  • If you’re below the threshold, you can still choose pre-tax or Roth catch-ups (Investopedia, 2025).


Why the change?


Congress designed the Roth-only rule (SECURE 2.0 §603) partly as a revenue raiser—taxes are paid now instead of deferred (NAPA, 2025). Regulators have now locked in the operational details (IRS; Federal Register).


The good, the bad, and the planning


The good:


  • Roth catch-ups can be powerful if you expect higher future tax rates, value tax-free RMD-free growth in a Roth 401(k)/Roth IRA (via rollovers), or want tax-efficient legacies for heirs (MarketWatch, 2025).


The bad:


  • Losing the upfront deduction can sting—especially if you’re in a high marginal bracket today (WSJ, 2025).

  • Plans without a Roth option may block catch-ups until they add one (Investopedia, 2025).


The planning angle: This isn’t just about losing a deduction—it’s a lifetime tax-location decision. Paying tax now to reduce future tax risk can make sense for many, but not all. Your income variability, retirement timeline, state taxes, and charitable goals all matter.


Practical moves to consider before 2026


  1. Confirm your wage status early. Ask HR or payroll where you’ll land relative to the $145,000 (indexed) threshold based on current-employer W-2 wages. If you’ll be above it, assume Roth-only catch-ups in 2026 (IRS; Nixon Peabody, 2025).

  2. Make sure your plan offers a Roth option. If it doesn’t, nudge your employer/administrator now. Otherwise, you could lose catch-up ability next year (Investopedia, 2025).

  3. Model the tax tradeoff. Run side-by-side scenarios:

    • Pre-tax 2025 catch-ups (last year for the deduction for many high earners)

    • Roth-only 2026+ catch-upsInclude your state taxes, expected retirement bracket, and whether Roth conversions are in your plan (The Tax Adviser, 2025; MarketWatch, 2025).

  4. Coordinate with IRAs and conversions. Roth 401(k) catch-ups in 2026+ can dovetail with Roth conversion strategy (e.g., fill lower brackets in gap years, manage Medicare IRMAA). Sequence matters.

  5. Revisit cash flow and withholding. No deduction in 2026 means higher current-year tax. Adjust withholdings/estimates now to avoid surprises (IRS general guidance).

  6. If you’re 60–63 in 2026+: Explore the “super catch-up” (150% of the standard catch-up). It’s Roth-only if you’re over the wage threshold—but can meaningfully boost tax-free savings in a short window (MarketWatch, 2025; The Tax Adviser, 2025).

  7. Mind the employer-specific rule if you switch jobs. The wage test applies to the employer sponsoring the plan (not combined across employers), which can produce different results after a job change (Nixon Peabody, 2025).


Quick example


A 55-year-old earns $190,000 W-2 wages in 2025 and maxes their plan in 2026.


  • Before 2026: They could do pre-tax catch-ups and lower their taxable income.

  • In 2026: Their catch-ups must be Roth, so current taxes rise—but future withdrawals can be tax-free. Whether that’s better depends on expected retirement tax rates, state taxes, and legacy goals.


Bottom line


This rule change is more than an administrative tweak. It’s a shift in when you pay tax on some of your most valuable retirement dollars. For many high-earning 50-somethings, 2025 is the last year to grab pre-tax catch-up deductions; after that, plan for Roth-only catch-ups and adjust cash flow, withholding, and your broader tax plan accordingly (IRS; Federal Register; The Tax Adviser, 2025).


If you want help deciding whether Roth-only catch-ups strengthen your plan—or how to pair them with conversions, charitable strategies, or legacy planning—let’s map it out together.



Sources:

  1. “Catch-Up Contributions.” Federal Register, 16 Sept. 2025, www.federalregister.gov/documents/2025/09/16/2025-17865/catch-up-contributions.

  2. Groom Law Group. “IRS Issues Final Regulations on Catch-Up Rule Changes.” Groom.com, 2025, www.groom.com/resources/irs-issues-final-regulations-on-catch-up-rule-changes/.

  3. Internal Revenue Service. “Treasury, IRS Issue Final Regulations on New Roth Catch-Up Rule and Other SECURE 2.0 Act Provisions.” IRS.gov, 15 Sept. 2025, www.irs.gov/newsroom/treasury-irs-issue-final-regulations-on-new-roth-catch-up-rule-other-secure-2point0-act-provisions.

  4. “IRS Announces Administrative Transition Period for New Roth Catch-Up Requirement; Catch-Up Contributions Still Permitted After 2023.” IRS.gov, 3 July 2025, www.irs.gov/newsroom/irs-announces-administrative-transition-period-for-new-roth-catch-up-requirement-catch-up-contributions-still-permitted-after-2023.

  5. Notice 2023-62. 2023, www.irs.gov/pub/irs-drop/n-23-62.pdf.

  6. MarketWatch. “IRS Rules Now Say 401(k) Catch-Ups for High Earners Have to Be in a Roth. Is It Still Worth It?” MarketWatch, 2025, www.marketwatch.com/story/irs-rules-now-say-401-k-catchups-for-high-earners-have-to-be-in-a-roth-is-it-still-worth-it-4b2f07bd.

  7. NAPA (National Association of Plan Advisors). “Breaking News: IRS Releases Final Roth Catch-Up Regulations.” NAPA-Net.org, 15 Sept. 2025, www.napa-net.org/news/2025/9/breaking-news-irs-releases-final-roth-catch-up-regulations/.

  8. Nixon Peabody. “IRS Finalizes New 401(k)/403(b) Catch-Up Contribution Regulations.” NixonPeabody.com, 24 Sept. 2025, www.nixonpeabody.com/insights/alerts/2025/09/24/irs-finalizes-new-401k403b-catchup-contribution-regulations.

  9. The Tax Adviser. “IRS Finalizes Regulations for Roth Catch-Up Contributions under SECURE 2.0.” TheTaxAdviser.com, 15 Sept. 2025, www.thetaxadviser.com/news/2025/sep/irs-finalizes-regulations-for-roth-catch-up-contributions-under-secure-2-0/.

  10. WSJ. “High Earners Age 50 and Older Are About to Lose a Major 401(k) Tax Break.” The Wall Street Journal, 24 Sept. 2025.

  11. Investopedia. “This 401(k) Change Could Impact How You Make Catch-Up Contributions.” Investopedia, 25 Sept. 2025.


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