Overview

• Workers with prior‑year FICA wages above an indexed $145,000 must make any catch‑up contributions as Roth starting in the 2026 taxable year.
• If a plan lacks a Roth feature, affected participants must be barred from making catch‑up contributions despite being age‑eligible.
• Participants who attain ages 60–63 can make larger super catch‑ups after 2024, equal to the greater of $10,000 or 150% of the regular catch‑up limit, subject to universal‑availability rules across controlled groups.
• The final regulations allow limited wage aggregation across common paymasters, controlled‑group employers, and certain predecessor‑successor situations to determine who crosses the threshold.
• Correction pathways remain for mistaken pre‑tax catch‑ups, including transfers to designated Roth or in‑plan Roth rollovers, with small‑amount exceptions and good‑faith reliance until the rules’ formal effective dates.