Frequently Asked Questions: SECURE 2.0 Roth Catch-Up

Changes to the SECURE 2.0 Act will impact certain participants making catch-up contributions to your retirement plan beginning January 1, 2026.

Below are some of the “Frequently Asked Questions” we have seen regarding SECURE Act 2.0- Roth Catch-up.

What is the SECURE Act 2.0?

The SECURE Act 2.0 is a federal law passed in December 2022 that made several changes to retirement savings rules. One major change affects “catch-up contributions” for employees age 50 and older who contribute to employer-sponsored retirement plans like 401(k), 403(b), or 457(b) plans.

What are catch-up contributions?

Catch-up contributions allow employees age 50 or older to contribute extra money to their retirement plan beyond the standard annual limit. For example, in 2025, the regular limit is $23,500. The catch-up limit allowed an additional $7,500, for a total possible contribution of $31,000.

Please Note: Some catch-up limits have increased for the 2026 plan year. The new limit for 401(k) and 403(b) employees age 60-63 is $11,250. The new limit for SIMPLE Plan employees age 60-63 is $5,250.

What changed under SECURE Act 2.0?

Beginning in the 2026 tax year, employees that are age 50 or older and earned more than $150,000 (indexed for inflation) in FICA wages from their current employer in the previous year (2025) must make their catch-up contributions on a Roth (after-tax) basis.

Who is affected by this new Roth catch-up rule?

This rule only applies to employees age 50 or older, and whose prior-year (2025) FICA wages from their employer sponsoring the plan exceed $150,000 (adjusted annually for inflation).

When does the Roth catch-up requirement take effect?

Originally scheduled for 2024, the IRS issued a two-year administrative delay, so enforcement begins in 2026. This means:

• 2023–2025: You can still make catch-up contributions as pre-tax or Roth, regardless of income.
• 2026 and beyond: If you earned more than $150,000 in the prior year, your catch-up contributions must be Roth.

What if my employer’s plan doesn’t offer a Roth option?

If a plan does not offer Roth contributions, high earners will not be able to make catch-up contributions at all under the new rule. The plan can, however, amend their documents to allow a Roth option as of 2026. This amendment would need to be completed before the first of December 2025 to allow for notices to be sent to employees.

Does this change affect my regular (non–catch-up) contributions?

No. The Roth requirement applies only to catch-up contributions. You can still choose between pre-tax or Roth for your regular deferrals, regardless of income.

Additional Content

To help you better understand the SECURE Act 2.0 Roth Catch-up changes, we recommend reading these additional blog posts:

Overview: SECURE Act 2.0 Roth Catch Up Provision

Employer Scenarios: SECURE Act 2.0 Roth Catch Up Provision