Beginning January 1, 2026, a key provision of the SECURE Act 2.0 will take effect that reshapes how retirement plan catch-up contributions are handled. Known as the SECURE 2.0 Roth catch-up rule, this change will require anyone age 50 or older who earned more than $145,000 in wages from their employer in the previous year to make all catch-up contributions as Roth contributions.

Originally slated for 2024, the rule was delayed by the IRS to give plan sponsors, administrators, and payroll providers time to prepare. That grace period is ending—and now is the time to prepare.

What Plan Sponsors and Trustees Must Do Now

For plan sponsors and trustees, the SECURE 2.0 Roth catch-up rule has immediate governance implications.

Amending Plan Documents and Adding Roth Features

If your plan does not already offer a Roth feature, sponsors should review and determine if they want to allow Roth payroll deferrals. Otherwise, affected participants will be unable to make catch-up contributions at all. Plan documents will need to be amended so that payroll and recordkeepers must be ready to track and code contributions correctly.

Governance and Fiduciary Considerations

Committees should ensure this issue is documented in compliance and governance records well before the deadline. Waiting until late 2025 to act will be too late if sponsors decide to amend the plan rules.

Payroll and Administrative Challenges Ahead

Administrators and payroll professionals will face some of the steepest challenges under this new rule.

Identifying Eligible Employees Each Year

Because the rule hinges on prior-year wages, payroll must reliably flag employees who exceed the threshold each January. That requires precise data exchange between payroll systems and recordkeepers.

Updating Systems and Communicating Changes

Updated payroll codes, exception-handling procedures for employees changing jobs, and clear employee communications are all essential. Participants approaching or over the threshold will need straightforward explanations of why their catch-ups must be Roth-only beginning in 2026.

Navigating the payroll and administrative changes required by the SECURE 2.0 Roth catch-up rule can feel overwhelming. Our Corporate Advantage Retirement Solutions help employers manage these transitions with confidence—handling compliance, fiduciary responsibilities, and participant education—so you can focus on running your business while your team secures their financial future.

What This Means for Participants Over Age 50

This change isn’t only about administrative complexity—it has real implications for individuals planning for retirement.

The Trade-Off: Higher Taxes Now, Tax-Free Withdrawals Later

If you are age 50 or older and consistently earn above $145,000, you will no longer be able to make pre-tax catch-up contributions beginning in 2026. That means higher taxable income in the year you contribute. But the trade-off is valuable: Roth contributions provide greater tax diversification in retirement, since qualified withdrawals are tax-free.

Why Roth Diversification Matters for Retirement Planning

Tax diversification is a powerful planning tool. By holding both pre-tax and Roth assets, you gain more flexibility to manage your taxable income in retirement. For higher earners who expect to remain in a high tax bracket later in life, this shift could ultimately work in their favor.

Preparing for 2026: Key Takeaways

Here’s how each group can begin preparing today:

Steps for Plan Sponsors

• Add a Roth option to your plan if it doesn’t already exist.
• Amend plan documents and update fiduciary records.

Steps for Administrators

• Update payroll and recordkeeping systems to apply the wage test each year.
• Create processes for employees who change jobs or compensation levels.
• Communicate changes clearly to affected employees.

Steps for Participants

• Review your contribution elections before 2026.
• Adjust withholdings if necessary to account for higher taxable income.
• Revisit your overall retirement strategy to determine how Roth savings fit in.

Final Thoughts

The SECURE 2.0 Roth catch-up rule is simple in concept—high earners must use Roth for catch-up contributions—but complex in execution. Plan sponsors should act now to ensure Roth is available, administrators must refine payroll systems, and participants should prepare for the tax shift and revisit their long-term retirement strategies.

With only a few months before implementation, the time to prepare is now.

Connect with us to review how the SECURE 2.0 Roth catch-up rule may affect your retirement strategy.