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IRS Finalizes Roth-Only 401(k) Catch-Up Rule for High Earners With 2027 Mandate

Employers must shift eligible workers’ catch-up contributions to after-tax Roth treatment by 2027, with a good-faith option to implement in 2026.

Overview

  • Workers aged 50 and over with prior-year wages above $145,000 will have to make 401(k) catch-up contributions on a Roth basis, with the income threshold indexed to inflation.
  • Plans may adopt the change in 2026 using a reasonable, good-faith interpretation, and full compliance becomes mandatory in 2027.
  • High earners in plans without a Roth 401(k) feature may be unable to make any catch-up contributions under the new rules.
  • Roth treatment shifts taxes to the contribution year, potentially increasing current tax bills and pushing some savers into higher brackets, while qualified withdrawals in retirement are tax-free.
  • For 2025, catch-up limits are $7,500 for those 50+ and $11,250 for ages 60–63, with inflation adjustments expected as more plans add Roth options in response.