SECURE 2.0 Roth Catch-up Provision for Retirement Plan Participants

Dec 10, 2025

Beginning on January 1, 2026, if you earned more than $150,000* in FICA wages (Box 3 of Form W-2) from your current employer in the prior calendar year, any Age 50+ Catch-up Contributions you make to your retirement plan may no longer be made as pre-tax contributions – they may only be made as Roth contributions and you will be deemed to have elected to make any Catch-up Contributions on a Roth basis.

What do you need to do?

If you fit the criteria above, we have outlined some action steps you may need to take:

Review Your Contribution Strategy:

Evaluate your current contribution strategy and consider how the new Roth Catch-up requirement may impact you. You can learn more about the differences between pre-tax and Roth contributions and how they impact your take home pay by visiting the Contribution Options Guide.

Consult a Financial Advisor:

If you deem appropriate for your specific situation, seek advice from a financial advisor to understand the tax implications of Roth contributions and how they fit into your overall retirement strategy. You can schedule a no-cost conversation here or by calling 844.253.8692.

Adjust Your Contributions:

With the new requirement, you can make pre-tax contributions only up to the 402(g) IRS limit ($24,500 in 2026). If you currently contribute a mix of pre-tax and Roth contributions up to the combined 402(g) and Catch-up Contribution limit ($32,500 in 2026), you may wish to update your contribution percentages for 2026 to account for the restriction on pre-tax Catch-up Contributions.

If you have any questions about how your Catch-up Contributions are being allocated, reach out to your Plan Administrator.

IMPORTANT:

If your FICA wages (Box 3 of Form W-2) earned in 2025 from your current employer do not exceed $150,000 or your wages from your employer are not subject to FICA, this new rule will not apply to you, and you will continue to have the choice of making Catch-up Contributions as pre-tax and/or Roth in 2026.

Please reach out to the ABA Retirement Funds Program with any questions.

*This FICA wage threshold is subject to annual cost-of-living adjustments and therefore may be adjusted annually by the IRS.

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.