What is the Roth Catch-Up Rule SECURE 2.0?
The Roth catch-up rule under SECURE 2.0 generally requires certain employees who will be age 50 or older by the end of the contribution year to make eligible catch-up contributions as Roth (after-tax) contributions instead of pre-tax contributions. Beginning in 2026, this rule generally applies if your prior-year Social Security wages (FICA wages) from the same employer exceed the IRS threshold.
This guide reflects IRS guidance available as of July 2026 and explains the rule for 2026 catch-up contributions, using 2025 wages to determine whether the Roth requirement applies.
Last updated July 22, 2026
Written by: Darryl Albuquerque
In this article
Why did the Roth catch-up rule change?
The Roth catch-up rule changed because SECURE 2.0 now requires certain higher-income employees to make eligible catch-up contributions on a Roth (after-tax) basis instead of a traditional pre-tax basis.
Before SECURE 2.0, eligible employees could generally choose between pre-tax and Roth catch-up contributions if their employer’s retirement plan offered both options. Although the rule was originally scheduled to take effect in 2024, the IRS provided transition relief, and the Roth catch-up requirement generally begins with 2026 catch-up contributions for affected employees.
The next question is whether the requirement applies to you.
Do I have to follow the Roth catch-up rule?
For 2026, you are generally subject to the rule if you are eligible for catch-up contributions in a covered plan and your 2025 Form W-2 Box 3 wages from the plan sponsor exceeded $150,000. Certain plans may aggregate wages from specified related employers.
Before looking at the details, use the checklist below to see whether the rule is likely to apply to you.
Roth catch-up rule eligibility checklist (2026)
- You will be age 50 or older by December 31, 2026, and your retirement plan permits catch-up contributions.
- Your 2026 elective deferrals are treated as catch-up contributions under your plan (for example, after exceeding the US$24,500 elective deferral limit).
- Your 2025 Form W-2 Box 3 (Social Security) wages from the same plan sponsor exceeded US$150,000 (as indexed by the IRS, if applicable).
If all conditions apply and the plan offers Roth catch-up contributions, your catch-up contributions generally must be Roth. If the plan has no Roth feature, you may be unable to make catch-up contributions.
How do I check the US$150,000 Roth catch-up threshold?
For 2026, use your 2025 Form W-2 Box 3 (Social Security wages) from the employer sponsoring your retirement plan. If those wages exceeded US$150,000, the mandatory Roth catch-up rule may apply if you otherwise qualify.
Example 1: Your 2025 Form W-2 Box 3 wages were US$150,000. You generally are not subject to the mandatory Roth catch-up rule for 2026 because your wages did not exceed the threshold.
Example 2: Your 2025 Form W-2 Box 3 wages were US$150,001. If you otherwise qualify for catch-up contributions, the mandatory Roth catch-up rule generally applies for 2026.
Special situations:
New hire in 2026: If you had no 2025 Form W-2 Box 3 wages from the employer sponsoring the plan, you generally are not subject to the mandatory Roth catch-up rule for that employer’s plan.
Related employers: Some retirement plans aggregate wages from related employers. If you worked for affiliated companies, ask your plan administrator whether those wages are combined when applying the threshold.
Which retirement plans does the Roth catch-up rule affect?
The Roth catch-up rule applies to certain employer-sponsored retirement plans. If you contribute to one of the retirement plans below and meet the eligibility requirements, the Roth catch-up rule may apply to your catch-up contributions.
Retirement plans covered by the Roth catch-up rule
|
Retirement plan |
Covered by the Roth catch-up rule? |
Notes |
|
401(k) |
Yes |
If the plan permits catch-up contributions. Beginning in 2026, eligible higher-income participants generally must make catch-up contributions as Roth if the plan has a Roth feature. |
|
SIMPLE 401(k) |
Yes |
Subject to the same Roth catch-up rule if the plan has a Roth feature. |
|
403(b) |
Yes |
Covered under the same rules as 401(k) plans. |
|
Governmental 457(b) |
Yes |
Covered if the plan permits catch-up contributions and has a Roth feature. |
|
Federal Thrift Savings Plan (TSP) |
Yes |
Covered under the SECURE 2.0 Roth catch-up rules. |
|
Traditional IRA |
No |
IRA catch-up contributions are not affected by this rule. |
|
Roth IRA |
No |
Roth IRA contribution rules are separate from employer-sponsored retirement plans. |
|
SIMPLE IRA |
No |
Excluded from this SECURE 2.0 provision. |
|
SEP IRA |
No |
Employer contribution arrangement; catch-up contribution rules do not apply. |
|
SARSEP |
No |
Excluded from this SECURE 2.0 provision. |
|
Foreign pension plans |
Check the plan |
Generally outside this SECURE 2.0 provision. Treatment depends on the specific plan and applicable tax rules. |
Note: Even if a retirement plan is covered, participants can generally make Roth catch-up contributions only if the plan offers a Roth contribution feature.
Am I exempt from the Roth catch-up rule?
For 2026, you generally are not subject to the mandatory Roth catch-up rule if any of the following apply:
- Your 2025 Form W-2 Box 3 (Social Security) wages from the same plan sponsor were US$150,000 or less.
- You had no 2025 Form W-2 Box 3 wages from that plan sponsor (for example, you were a new employee in 2026).
- Your 2026 elective deferrals are not treated as catch-up contributions under your retirement plan.
- You contribute only to an excluded account, such as a traditional IRA, Roth IRA, SEP IRA, or SIMPLE IRA.
If you’re unsure whether the rule applies, your employer or retirement plan administrator can usually confirm whether your catch-up contributions must be made on a Roth basis.
Also read: Traditional IRA or Roth IRA?
How does the Roth catch-up rule affect Americans living abroad?
Living abroad does not automatically exempt you from the Roth catch-up rule. Whether it applies depends on the type of retirement plan you participate in and your prior-year Form W-2 Box 3 (Social Security) wages from the plan sponsor.
- Covered US employer plan: he rule may apply if you meet the eligibility requirements, including the prior-year wage test.
- Foreign pension or retirement plan: These plans are generally outside this SECURE 2.0 provision.
If you’re a US expat, follow these steps:
Step 1: Confirm whether you’re participating in a covered US employer retirement plan.
Step 2: Check your 2025 Form W-2 Box 3 (Social Security) wages from the employer sponsoring the plan.
Step 3: Ask your plan administrator whether wages from related employers are aggregated.
Step 4: Verify that your plan offers a Roth contribution feature.
What mistakes should I avoid?
The main mistake is treating the Roth catch-up rule as broader than it is.
- Applying it to all retirement contributions: It affects only eligible catch-up contributions.
- Using total income: The rule is based on prior-year wages from the sponsoring employer.
- Assuming foreign residence creates an exemption: Living abroad does not prevent the rule from applying to a covered US employer plan.
Frequently Asked Questions
Can my employer still offer pre-tax catch-up contributions?
It depends. If the Roth catch-up rule applies to you, eligible catch-up contributions must generally be made on a Roth basis. However, employees who don’t meet the rule’s requirements may still be able to make pre-tax catch-up contributions if their retirement plan allows it.
What happens if I change employers?
If you change to an unrelated employer and had no wages from that employer in the prior year, you generally will not be subject to the Roth catch-up requirement under its plan for the current year. Ask the plan administrator whether any related-employer or successor-employer aggregation rule applies.
Do employer matching contributions have to be made as Roth contributions?
No. The Roth catch-up rule applies only to eligible employee catch-up contributions. Employer matching contributions follow separate IRS rules and aren’t automatically required to be Roth because of this provision.
Does the Roth catch-up rule change how much I can contribute?
The Roth requirement itself changes tax treatment, not the limit. Separately, SECURE 2.0 provides a higher catch-up limit for ages 60 through 63.
What if my retirement plan doesn’t offer Roth contributions?
If your plan does not offer a Roth feature and you are subject to the mandatory Roth rule, you generally cannot make catch-up contributions under that plan. Confirm the plan’s terms with the administrator.
Do self-employed individuals have to follow the Roth catch-up rule?
A self-employed person with only net earnings from self-employment and no Form W-2 Box 3 wages from the plan sponsor generally is not subject to the mandatory Roth catch-up rule. The result can differ if the person also receives FICA wages from the employer sponsoring the plan.
Prefer to talk it through? Schedule your free callback today.
Darryl Albuquerque, an IRS Enrolled Agent, brings 22 years of expat tax expertise in US tax preparation for Americans and Green Card holders living abroad.
Darryl also specializes in streamlined offshore filing and tax advisory services for American citizens, permanent residents, and foreign nationals living abroad.
