Beginning January 1, 2026, federal law changes how certain employees age 50 or older can make catch-up contributions to their 401(k).

If the new rule applies to you, your catch-up contributions must be made as Roth contributions.

Does this apply to me?

For 2026, the Roth catch-up requirement generally applies if:

  • You will be age 50 or older by December 31, 2026; and
  • You had more than $150,000 in Social Security wages from your employer during 2025.

For most employees, Social Security wages can be found in Box 3 of your 2025 Form W-2.

If your Box 3 wages were exactly $150,000, you are not subject to the mandatory Roth catch-up requirement for 2026.

The IRS may adjust the wage threshold in future years.

What is a catch-up contribution?

If you're age 50 or older, the IRS allows you to contribute additional money to your 401(k) beyond the regular annual contribution limit.

These additional contributions are called catch-up contributions.

What does it mean if my catch-up contributions must be Roth?

Roth contributions are made with money that has already been included in your taxable income.

If you're subject to the new requirement, only your catch-up contributions must be Roth. Your regular 401(k) contributions do not automatically have to change from pre-tax to Roth.

Do I have to make catch-up contributions?

No. Catch-up contributions are optional.

However, if you are subject to the Roth catch-up requirement and choose to make catch-up contributions, those contributions must be Roth.

You cannot choose to make your required Roth catch-up contributions on a pre-tax basis.

Do I need to change my current 401(k) election?

Not necessarily.

The new rule does not automatically require you to change your regular 401(k) contribution election. It affects how your catch-up contributions must be treated if you are subject to the requirement.

What if I earned more than $150,000 from a different employer in 2025?

Wages from an unrelated previous employer generally do not count toward the Roth catch-up wage threshold for your current employer's plan.

For example, if you started with your current employer in 2026 and had no 2025 Social Security wages from that employer, wages from an unrelated employer generally would not cause you to be subject to the Roth catch-up requirement for 2026.

What if I'm age 60 through 63?

Employees ages 60 through 63 may qualify for a higher catch-up contribution limit.

This is separate from the Roth requirement. Whether your catch-up contributions must be Roth still depends on your applicable Social Security wages from the previous year.

What do I need to do?

Your employer will determine whether you are subject to the Roth catch-up requirement using your prior-year Social Security wages.

If you are affected, make sure you understand how your catch-up contributions will be treated and review your contribution election if you want to change how much you contribute.

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