Q: Erick, can you provide clarification on the SECURE Act 2.0 mandatory Roth catch-up provision for high earners?
A: This was confusing for many employers as well as for the 401k industry. In 2026, mandatory Roth catch-up contributions for high-earning employees age 50 or older will become effective. Specifically, if an individual’s FICA wages from the same employer sponsoring the plan exceeded $145,000 in the prior calendar year (indexed annually), then any “catch‑up” contributions they elect must be made on an after‑tax Roth basis for 401(k), 403(b) or governmental 457(b) plans. If a plan does not have an existing Roth provision, they are not required to add it, but they will not be able to allow those employees to use the existing catch-up contribution provision in the plan.
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Disclosures, Sources, and Footnotes
For plan sponsor use only, not for use with participants or the general public. This information is not intended as authoritative guidance or tax or legal advice. You should consult with your attorney or tax advisor for guidance on your specific situation.
©2025 Kmotion, Inc. All rights reserved. This newsletter is a publication of Kmotion, Inc., whose role is solely that of publisher. The articles and opinions in this newsletter are those of Kmotion. The articles and opinions are for general information only and are not intended to provide specific advice or recommendations for any individual. Nothing in this publication shall be construed as providing investment counseling or directing employees to participate in any investment program in any way. Please consult your financial advisor or other appropriate professional for further assistance with regard to your individual situation.
RP-276-0825 Tracking #781124
