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The Finance Base
401(k)

Roth 401(k) Catch-Up Rule Starts in 2026 for Higher-Wage Earners

The 2026 Roth catch-up rule applies to eligible participants whose 2025 FICA wages from their plan sponsor exceeded $150,000. It affects catch-up dollars, not regular deferrals.

By TheFinanceBase Team 3 min read
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Starting with contributions in 2026, eligible employees whose 2025 FICA wages from the employer sponsoring their plan were more than $150,000 must make any catch-up contributions as designated Roth contributions—if their plan permits catch-ups and offers a Roth feature. The requirement applies to catch-up dollars, not to regular 401(k) deferrals up to the standard limit.

Who must make catch-up contributions as Roth?

The rule applies to participants eligible to make catch-up contributions under an employer plan who exceed the applicable prior-year wage threshold. For 2026 contributions, compare your 2025 FICA wages from the employer sponsoring the plan with $150,000. The test is based on wages under the statutory FICA definition—not household income or adjusted gross income. The IRS describes the threshold as wages that exceeded $150,000, so wages of exactly $150,000 do not cross it. IRS participant guidance and the IRS final regulations describe the rule and wage measure.

Catch-up eligibility generally begins at age 50, subject to plan rules. The IRS regulations also address wage attribution in special situations, including multiple employers and multiemployer plans. If your employment history or plan arrangement is unusual, ask the plan administrator how it applies those rules.

What are the 2026 contribution limits?

The following federal limits apply to most 401(k), 403(b), governmental 457 plans and the Thrift Savings Plan. Your plan must permit catch-ups, and plan or compensation limits may reduce what you can contribute.

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Contribution type 2026 federal limit Who it applies to
Regular elective deferrals $24,500 Most participants in the listed plans
General age-50 catch-up $8,000 Eligible participants age 50 or older, subject to plan rules
Higher age-60-to-63 catch-up $11,250 Eligible participants who attain age 60, 61, 62 or 63 during 2026

The IRS announced the regular and general catch-up limits for 2026 in its 2026 contribution-limit guidance; the higher age-60-to-63 limit is addressed in the final regulations and limit rules. A catch-up is the amount above the applicable regular elective deferral limit or another applicable limit, as determined under the plan—not an automatic extra amount every participant can contribute.

What changes for Roth and pretax contributions?

If the rule covers you, your catch-up contributions must be designated Roth when your plan offers a Roth feature. Roth deferrals are made after tax, unlike pretax deferrals, which generally reduce taxable income when contributed. The requirement does not make your ordinary deferrals up to the $24,500 regular limit Roth; the rule applies only to the catch-up portion.

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Because Roth catch-ups are after-tax contributions, changing an election can affect current take-home pay and taxes. The personal impact depends on your circumstances; the federal rule does not determine which tax treatment is best for you.

Does “starts in January 2026” conflict with the regulation’s later date?

No. The IRS participant guidance describes the Roth catch-up requirement as beginning in 2026. The final regulations are effective November 17, 2025, but generally apply to contributions in taxable years beginning after December 31, 2026. Those are distinct dates: the later general applicability date for the final regulations does not mean the statutory Roth catch-up requirement has been postponed beyond 2026. See the IRS participant page and final regulations.

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What should you check before changing your election?

  1. Check the wage test. Look at your 2025 FICA wages from the employer sponsoring your plan and determine whether they exceeded $150,000. If you are unsure which wages count, ask payroll or the plan administrator.
  2. Confirm plan options. Review your plan notice or ask whether it permits catch-up contributions and offers designated Roth contributions.
  3. Review payroll instructions. Follow the plan administrator’s instructions for making or updating your deferral election, including how catch-up contributions are identified.
  4. Consider the tax impact. Account for the after-tax treatment of Roth catch-ups when evaluating your current-year withholding and take-home pay.

The federal guidance sets the rule, but your actual elections depend on your employer plan’s terms and administration. IRS materials do not establish whether a particular employer, recordkeeper or payroll platform has completed its implementation.

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