Overview

• Final regulations released September 16 confirm plans must operationalize the Roth catch-up mandate in 2026, with the rules legally effective for taxable years beginning after December 31, 2026 and no further transition relief.
• The Roth-only catch-up applies to participants with prior‑year FICA wages above $145,000 (indexed), based on the employer sponsoring the plan, with limited aggregation for common paymasters, controlled groups, and predecessor/successor employers.
• Plans that lack a Roth feature must bar affected participants from making catch-ups, with deemed nondiscrimination relief if certain highly compensated partners are also restricted.
• Plans may use deemed Roth catch-up elections if participants have an effective opportunity to choose differently and must cease the deeming when it no longer applies; regulators preserved correction paths via W‑2 reporting or in‑plan Roth rollovers.
• The rules reaffirm ‘super’ catch-ups for ages 60–63 (greater of $10,000 or 150% of the standard limit) and clarify universal availability across controlled groups, while coverage notes high earners will trade a current tax hit for potential tax‑free growth.