The 2026 Roth Catch-Up Rule and the $150,000 Line
• From 2026: if your wages with your employer were above $150,000 last year, your 401(k) catch-up contributions must go in as Roth (after-tax), not pre-tax.
• The 2027 you read elsewhere is when the IRS final regulations formally bind plan administrators — not when your obligation starts.
• At or under $150,000? Nothing changes for you in 2026.
Few 401(k) changes have generated more confusion than the SECURE 2.0 “mandatory Roth catch-up.” Half the internet says it starts in 2026, the other half says 2027. Here is the resolution, from the IRS itself: both dates are real — they just apply to different people.
The rule, in plain English
Catch-up contributions are the extra amounts savers 50+ can put into a 401(k) — $8,000 in 2026, or $11,250 at ages 60–63. Historically you could make them pre-tax. SECURE 2.0 changed that for high earners.
The IRS states it directly: “beginning in 2026, participants of plans with Roth features offering catch-up contributions must make catch-up contributions on a Roth basis if prior-year wages with the plan sponsor exceeded $150,000” (threshold as set for 2026, indexed in future years).
The three details inside the $150,000 test
- Prior-year wages — for 2026, it is your 2025 wages that count.
- Same employer — the test looks at wages from the plan sponsor. If you changed jobs, wages from a previous employer do not count toward the new employer’s test.
- Roth means after-tax now, tax-free later — you lose today’s deduction on the catch-up, but qualified withdrawals of those dollars (and their growth) are tax-free.
So where does “2027” come from?
In September 2025 the IRS issued the final regulations for this rule (announced in IR-2025-91). Those regulations formally apply to plan administrators for “contributions in taxable years beginning after December 31, 2026” — that is, 2027 (with later dates for some governmental and collectively-bargained plans).
For 2026, the IRS instructs plans to apply the law using a “reasonable, good faith interpretation” of the statute. Translation: your obligation as a worker starts in 2026; the paperwork standard for plan administrators tightens in 2027. Articles that say the rule was “delayed to 2027” are misreading the applicability date of the regulations.
What to do before January
- Check your 2025 W-2 wages from your current employer against the $150,000 line.
- If you are over it and you make catch-up contributions, confirm your plan has a Roth option — and expect your catch-up to be redirected to Roth.
- If you are at or under it, your catch-up can stay pre-tax in 2026.
Sources
Educational content only — not financial, tax or legal advice. Figures and quotes verified against the sources above at the time of writing; always confirm on irs.gov before acting. Consult a qualified financial advisor about your situation.