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Starting in 2026, employees age 50+ whose prior-year FICA wages exceed the §414(v)(7)(A) threshold (statutory $145,000, indexed) MUST make their 401(k), 403(b), or 457(b) catch-up contribution as Roth. Check whether the mandate applies to you, and see the dollar-level tax math you would otherwise be choosing between.
Mandate
Subject (Roth required)
Allowed catch-up
$8,000
Tax cost now (Roth)
$2,560
10-yr after-tax delta
$3,127.48
A 55-year-old earning $180,000 at the same employer is over the $145,000 threshold, so the $8,000 catch-up must be Roth in 2026. Tax cost today at a 32% bracket: $2,560. After 10 years at 5% real return, the Roth pot grows tax-free to $13,031.16 vs $9,903.68 after-tax in a traditional account taxed at 24% in retirement — a $3,127.48 delta.
Source: FinCalc server-rendered example using the same formulas as the interactive calculator.
Your prior-year FICA wages ($180,000) exceed the $145,000 threshold. In 2026 your catch-up contribution MUST be Roth (after-tax). Your plan administrator should have notified you.
Allowed catch-up max for age 55: $8,000
Catch-up starts at 50. Super catch-up applies at ages 60–63 ($11,250).
W-2 box 3 (Social Security wages) from the employer sponsoring your 401(k). Wages from other employers do not aggregate under the final regs.
Statutory $145,000 (§414(v)(7)(A)), indexed for inflation each year. Confirm the 2026 figure with IRS Notice 2025-67 or your plan administrator.
Capped at $8,000 for your age. Above the base $24,500 deferral limit.
Use a real (inflation-adjusted) return so retirement-dollar comparisons stay apples-to-apples.
Mandate
Subject
Roth required
Allowed catch-up
$8,000
Standard 50+
Tax cost delta now
$2,560
Roth vs Traditional, this year
After-tax delta at retirement
$3,127.48
Roth wins (single year)
Comparing one year's catch-up of $8,000 grown for 10 years at 5.0% real return.
Roth catch-up
Traditional catch-up (counterfactual)
If you contribute $8,000 as catch-up every year for 10 years.
| Metric | Roth path | Traditional path |
|---|---|---|
| Total contributions | $80,000 | $80,000 |
| Tax saved during career | $0 | $25,600 |
| After-tax value at retirement | $100,623.14 | $76,473.59 |
Lifetime delta: Roth path ends up ahead of Traditional by $24,149.55 in after-tax retirement dollars.
You are subject to the mandate: catch-up must be Roth in 2026. Traditional would have been mathematically better given your higher bracket today, but the mandate removes the choice.
The mandate forces Roth regardless of your bracket math. But the comparison still tells you whether you are losing tax-planning flexibility or gaining a forced-savings advantage by going Roth.
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Section 603 of the SECURE 2.0 Act of 2022 amended Internal Revenue Code §414(v) to require that certain catch-up contributions to employer-sponsored plans be made as Roth (after-tax) contributions starting in 2026. The IRS issued final regulations on September 16, 2025 (RIN 1545-BR07), confirming the rule and resolving implementation questions. The mandate has three components: (1) a wage test, (2) an age test, and (3) a same-employer aggregation rule.
The wage test: prior-year FICA wages — specifically W-2 box 3 Social Security wages — from the employer that sponsors your retirement plan must exceed an indexed threshold. The statute set this at $145,000; the §414(v)(7)(A) indexing rules tie it to the §401(a)(17) cost-of-living adjustment, so the 2026 number will be modestly higher than $145,000 (sources cite figures in the $145,000–$150,000 range). Confirm the precise 2026 figure with IRS Notice 2025-67.
The age test: you must be age 50 or older by the end of 2026 to make catch-up contributions at all. The standard catch-up is $8,000. Ages 60–63 trigger an enhanced super catch-up of $11,250 (SECURE 2.0 § 109), and the Roth mandate applies to that amount too if you meet the wage test. The base elective deferral limit for 2026 is $24,500, with the catch-up stacked on top.
The same-employer rule: the wage test looks only at the employer sponsoring the plan you contribute to. Wages from a separate employer (with limited exceptions for common-law aggregated employers) do not count. Self-employed earners pay SECA, not FICA, and have no FICA wages from an employer — so the final regulations confirm the mandate does not apply to them. The mandate also does not apply to IRA catch-up contributions.
If you turn 60, 61, 62, or 63 during 2026, your catch-up limit jumps to $11,250 — roughly 40% more than the standard $8,000. At 64, it reverts back to the standard $8,000. The Roth mandate applies to the full enhanced amount when the wage test is met, so a 62-year-old earning over the threshold must put the full $11,250 in as after-tax Roth.
Data and assumptions align with official publications. For verification and current figures:
Anyone age 50+ in 2026 whose 2025 FICA wages (W-2 box 3) from the employer sponsoring the plan exceed the §414(v)(7)(A) threshold (statutory $145,000, indexed for inflation; sources cite figures in the $145,000–$150,000 range for 2026). If you meet both tests, your catch-up contribution to a 401(k), 403(b), or governmental 457(b) MUST be Roth in 2026.
The mandate is determined by prior-year wages from the SAME employer that sponsors your current plan. The IRS final regulations confirm wages from a different employer do not aggregate. If you started a new job in 2025 and earned under the threshold there, the mandate does not apply for 2026 — even if your total income from all employers exceeded the threshold.
No. The mandate applies only to 401(k), 403(b), and governmental 457(b) catch-up contributions. IRA catch-ups (an extra $1,000 for age 50+) are unaffected. You can still make a traditional IRA catch-up contribution regardless of your wages, subject to normal IRA deduction rules.
The test uses the full prior calendar year of FICA wages from that employer, not a prorated amount. If you started mid-2025 and earned $80,000 in five months at an annualized $192,000 pace, your actual 2025 W-2 wages of $80,000 still control. The annualized figure does not trigger the mandate.
Roth catch-up is contributing the $8,000 (or $11,250) directly as Roth via payroll. An in-plan Roth conversion converts already-saved pre-tax balances to Roth, generating a taxable event in the conversion year. The mandate only governs the catch-up contribution itself, not whether you also do conversions.
No. Self-employed earners (Schedule C, K-1) pay SECA tax, not FICA, and have no FICA wages "from an employer". The IRS final regulations clarify that the mandate does not apply to self-employed individuals. Solo 401(k) catch-up contributions can still be made pre-tax.
SECURE 2.0 § 109 created an enhanced catch-up for ages 60–63: $11,250 in 2026, replacing the standard $8,000 for those four years only. The Roth mandate applies to this enhanced amount too — if you are 60–63 AND over the wage threshold, the full $11,250 must be Roth.
If your 401(k) plan does not offer a Roth option and you are subject to the mandate, you simply cannot make catch-up contributions in 2026. The plan administrator must either add a Roth feature or deny catch-ups for high earners. Most major plans added Roth features in 2024–2025 specifically for this rule.
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