Roth catch-up contributions for individuals with FICA wages of $145,000 (as indexed) or more the prior calendar year are required to make the catch-up contributions as Roth catch-up contributions, not as traditional pretax contributions. This goes into effect on January 1, 2026.
Amounts contributed as Roth contributions are includible in gross income in the year of the contribution, but distributions from the account, including earnings, generally are tax-free. This requirement was originally due to take effect in 2024 but was delayed until 2026 due to concerns that plans and service providers could not change their administrative and recordkeeping procedures in time to comply.
Under SECURE 2.0, participants attaining ages 60-63 during the taxable year may make additional tax-preferred contributions to their retirement savings, known as “super catch-up contributions.” Higher earners must follow the Rothification requirement for both catch-up and super catch-up contributions.
Plans without a Roth option: Plans are not required to include a Roth option. For plans with a catch-up provision but no Roth option, catch-up contributions cannot be made.