The Mandatory Roth Catch-up Requirement Under SECURE 2.0 is in Effect for 2026 - Action Required
Under the SECURE 2.0 Act of 2022, catch-up contributions1 to your plan made by certain participants must be made on a Roth basis starting in 2026. We refer to this as the “mandatory Roth catch-up requirement.”
As plan administrator, you are responsible for complying with these new rules. The Program is here to help! Please read the information below carefully so that you are prepared to correctly handle contributions for your plan in 2026.
Which participants are subject to the mandatory Roth catch-up requirement?
For 2026, participants whose 2025 FICA wages from the employer sponsoring the plan exceeded $150,0002 (as reported in Box 3 of Form W-2) will be considered “mandatory Roth catch-up participants” or “MRC participants.”
A participant who did not have FICA wages from the employer sponsoring the plan for the preceding calendar year – such as a partner who had only self-employment income – will not be subject to the mandatory Roth catch-up requirement.
What do I need to do to comply with the mandatory Roth catch-up requirement?
MRC participants are not permitted to make catch-up contributions on a pre-tax basis.
Once an MRC participant has made pre-tax contributions equal to the elective contribution limit1, they will be deemed to have elected to make catch-up contributions on a Roth basis. A participant in this situation can change their contribution election to $0 if they do not wish to make catch-up contributions on a Roth basis.
As plan administrator, you are responsible for ensuring that any catch-up contributions to the plan for an MRC participant are made on a Roth basis once an MRC participant has made pre-tax contributions equal to the elective contribution limit, even if the affected participant elected to make pre-tax contributions. You must have practices and procedures in place that are designed to result in compliance with the new rules and you will need to work with your payroll provider.
How can the Program help?
The Program is here to help you with this change.
- Participant communication – In December, catch-up eligible participants will receive an email and/or letter describing the changes. Be sure to work with your MRC participants to help them understand the impact of these changes. You can share this article to help educate your participants.
Catch-up contribution monitoring – If you provide a list of your MRC participants to the Program, the Program will monitor contributions to their accounts and flag any catch-up contributions made on a pre-tax basis for resolution prior to posting the contribution to the participants’ account.
If you would like to notify the Program, we recommend providing a list of your MRC participants as soon as possible after year’s end. To notify the Program:
- Fill out the Participant Data Change Form (“Form”) and upload it to Sponsor Web using the Upload Document button under the Plan Resources tab.
- If you have not yet established access to Sponsor Web, you will receive an email notice from Sponsorweb@voya.com prior to year’s end with your account information. Please follow the instructions on this notice to register your Sponsor Web account. If you need any help, please reach out to the Program.
- If you are not able to establish access to Sponsor Web, you may deliver the Form to the Program according to the Form’s instructions.
Please note: You must review your list of MRC participants each year. If a participant should no longer be identified as an MRC participant, you must submit an updated Participant Data Change Form to Sponsor Web. If you do not, prior year designations will remain for subsequent years, and this could cause an operational error for your plan.
- Look for additional information and education in the new year – the Program will provide you with more information through email and within the Plan Admin Guide and Training & Education Library on abaretirement.com.
If you have any questions, please reach out to the Program.
1 Federal tax law limits the amount that a participant may elect to contribute to your plan on a pre-tax and/or Roth basis. For 2026, the elective contribution limit is $24,500. However, participants who are aged 50 and older may make catch-up contributions to your plan in excess of the elective contribution limit. For 2026, the regular catch-up contribution limit is $8,000, but a higher limit of $11,250 applies for participants who are age 60, 61, 62 and 63 in place of the regular catch-up contribution limit. Note: Contribution limits are subject to adjustment by the Internal Revenue Service in future years for changes in the cost of living.
2 The FICA wage threshold is subject to adjustment by the Internal Revenue Service in future years for changes in the cost of living.
Voya Financial Partners, Voya Financial Advisors and Voya Retirement Advisors are members of the Voya family of companies (“Voya”). Voya, the ABA Retirement Funds, Mercer Trust Company, Charles Schwab & Co., Inc., and state and local bar associations are separate, unaffiliated entities, and not responsible for one another’s products and services.
This material has been provided for educational purposes only. This material was created to provide accurate and reliable information on the subjects covered. It is not intended to provide specific legal, tax or other professional advice. The services of an appropriate professional should be sought regarding your individual situation.