As the SECURE 2.0 Act deadline for mandatory catch-up contributions for some plan participants looms, many retirement plan sponsors are beginning to amend their plan documents to meet its requirements. Under this SECURE 2.0 Act provision, plan participants aged 50 and older who meet certain higher earnings thresholds in the prior year must make any allowable catch-up contributions as designated Roth contributions. The applicable earnings threshold for 2026 is $150,000 in the prior year’s wages.
The mandatory Roth catch-up requirement originally applied to 2024, but the Internal Revenue Service (IRS) and the Treasury Department implemented transitional relief. As a result, the requirement became effective for contributions made in tax years beginning after December 31, 2025, which, for many plans, means January 1, 2026. More specifically, the catch-up requirement applies to contributions made in any taxable year that begins after December 31, 2026. Still, plans may implement the
