Super Catch-Up Roth Mandate — What Changed for High Earners

Super Catch-Up Roth Mandate — What Changed for High Earners

Two retirement rules meet for some workers in their early 60s: a higher “super catch-up” limit for ages 60 to 63, and a requirement that catch-up contributions from higher earners be made as Roth contributions. Both are specific and numerical, which makes them easy to plan around. This post lays out the 2026 limits, who the Roth requirement covers, what changes in practice, and a short plan for using the higher limit.

The 2026 Limits

The IRS announced on November 13, 2025 that the 401(k) deferral limit for 2026 is $24,500, up from $23,500. The catch-up for age 50 and older is $8,000, for a total of $32,500, and the catch-up for ages 60 to 63 is $11,250 instead of $8,000 (IRS).

Group2026 maximum
Under 50$24,500
Age 50+$32,500
Age 60–63$35,750

The age 60–63 total is $24,500 + $11,250 = $35,750, or $3,250 more than the standard catch-up total. Over four years at these 2026 amounts, standard catch-up would add up to $32,000 and the higher catch-up to $45,000, a difference of $13,000. That is my arithmetic and assumes the limits stay the same.

The Super Catch-Up Is Optional for Plans

McGuireWoods’ summary of the IRS final regulations says participants who reach age 60, 61, 62 or 63 during the tax year may contribute more under the enhanced limit, which for non-SIMPLE plans is the greater of $10,000 or 150% of the standard catch-up limit. Plans are not required to offer it. If offered, it must be available consistently to all eligible participants (McGuireWoods). For SIMPLE plans the 2026 age 60–63 catch-up is $5,250 (IRS).

Who Must Make Catch-Ups as Roth

Under the IRS final regulations released September 15, 2025, participants aged 50 or older whose prior-year FICA wages from the plan sponsor exceed the threshold must make catch-up contributions as Roth contributions. The wage threshold started at $145,000 and is adjusted annually for inflation (McGuireWoods). PlanSponsor reports that IRS Notice 2025-67 raised it from $145,000 to $150,000, and that the figure applies to 2026 catch-up decisions based on 2025 wages (PlanSponsor).

  • The requirement applies to the catch-up portion only. Your regular deferral up to $24,500 is not covered by it, according to the summaries above.
  • If a plan has no Roth feature, high earners may not be allowed to make catch-up contributions at all (McGuireWoods).
  • Plans may automatically treat high earners’ catch-ups as Roth, but participants must still be able to change or stop their elections (McGuireWoods).
  • Plans that offer catch-ups to high earners must allow all catch-up-eligible participants to make Roth catch-ups (McGuireWoods).

Timing

The IRS release on the final regulations says the Roth catch-up provisions generally apply to contributions in taxable years beginning after Dec. 31, 2026, and that plans may apply them earlier using a reasonable, good-faith reading of the statute; certain governmental plans and plans under collective bargaining agreements get later dates (IRS). Because applying the rule for 2026 is optional, whether your plan already treats 2026 catch-ups as Roth is a plan decision.

What It Means for Your Paycheck

A Roth catch-up is made with after-tax money, so it does not reduce this year’s taxable income the way a pre-tax contribution does. As an assumed example, a worker in the 24% federal bracket who makes the full $8,000 catch-up as Roth gives up a deduction worth $1,920 this year, and the full $11,250 super catch-up would be worth $2,700. The contribution limit itself is not reduced. The bracket and amounts are assumed for illustration.

Making a Plan

  • Find out if you are covered. The test is based on your prior-year FICA wages from the employer that sponsors the plan (McGuireWoods).
  • Ask whether your plan offers a Roth option and the super catch-up. The plan summary or administrator can tell you. Both are plan decisions.
  • Use the regular deferral first. You can use up to $24,500 for pre-tax or Roth saving as your plan allows, and add the catch-up on top.
  • Budget for the Roth catch-up. The take-home pay effect is the full amount, because there is no deduction, so spreading it across the year makes it smoother.
  • Look at your other accounts. The Roth IRA income range for single filers is $153,000 to $168,000 in 2026, and $242,000 to $252,000 for joint filers (IRS). The IRA limit is $7,500, with a $1,100 catch-up (IRS).

My Take on Super Catch-Up Roth Mandate

  • In my view, the helpful way to see the Roth catch-up is as a chance to build tax-free-withdrawal money alongside pre-tax savings, which gives you two tax buckets to draw from later. That is my reading, not a claim from the sources.
  • In my view, planning the take-home impact early, rather than at the first paycheck, avoids surprises.
  • In my suggestion, if you are close to the wage threshold, check your Form W-2 wage boxes each January, since the test uses the prior year.

Sources

Related reading: The Roth 401(k) Match Tax Surprise Has Two Completely Different Versions and The Same-Day Conversion Trick Behind the $47,500 Roth Move.

This article offers general information and my own opinions, not financial, tax, or legal advice. The figures in worked examples are assumed. Laws, tax rules, and products change and can differ by location, so check current official sources and talk to a qualified professional about your own situation.