Starting January 1, 2026, a SECURE 2.0 provision changes how high earners age 50+ can make catch-up contributions — and for many, it removes the pre-tax option entirely.
The 2026 Catch-Up Limits
Beyond the standard $24,500 employee deferral limit (see our full 2026 contribution limits guide), catch-up amounts for 2026 are tiered by age: participants 50–59 and 64+ can contribute up to $8,000 in catch-up money, while a new higher tier for ages 60–63 allows up to $11,250 — a SECURE 2.0 “super catch-up” specifically for that four-year window.
The Roth Mandate for High Earners
Under SECURE 2.0 Section 603, anyone age 50+ who earned more than $150,000 in FICA wages from their current employer in the prior year must make all catch-up contributions as Roth — after-tax dollars, no deduction now, tax-free withdrawals later. This isn’t optional and it isn’t about your overall income; it’s based specifically on FICA wages from that one employer. If you don’t proactively elect Roth, most plans will apply an IRS-approved deemed election and route the catch-up money to Roth automatically rather than rejecting the contribution.
Who This Actually Affects
The $150,000 threshold is measured on FICA wages, not gross salary or total household income — so a W-2 employee at that wage level trips the mandate even if their spouse’s income or personal deductions bring their overall tax picture lower. Self-employed people contributing to a Solo 401(k) fall under different mechanics since there’s no separate “employer” FICA wage to measure — check our Solo 401(k) vs. SEP-IRA guide for how catch-up contributions work in a self-employed plan.
Why This Matters Even If You Wanted Roth Anyway
If your Traditional-vs-Roth analysis already favored Roth, this mandate doesn’t change anything for you. But if you were counting on a pre-tax catch-up deduction to reduce this year’s taxable income — a common last-quarter tax move for high earners — that lever is now gone for the catch-up portion specifically. Your base $24,500 deferral can still go pre-tax; only the catch-up amount above that is forced to Roth once you cross the wage threshold.
The Bottom Line
If you’re 50+ and earned over $150,000 in FICA wages last year, check your 2026 payroll elections now. Plans handling this incorrectly, or employees who assumed their catch-up was still reducing taxable income, are the most common mistake this rule change produces in its first year.
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