High-Income Earner 401(k) Catch-Up Changes: What Employers Need to Know in 2026

Heads up, employers. Starting January 1, 2026, 401(k) catch-up contributions for high-income earners must be made on a Roth (after-tax) basis. If your plan doesn't offer a Roth 401(k) option, your highest-paid employees won't be able to make catch-up contributions at all. Here's what you need to know — and what to do before year-end.

What Changed?

The SECURE 2.0 Act (signed December 2022) introduced a major shift in how catch-up contributions work for higher-earning employees. Starting in 2026:

💡 Important: The $150,000 threshold is based on FICA wages from the employer sponsoring the plan — not household income or wages from other employers. This was adjusted from the original $145,000 due to inflation indexing.

2026 Catch-Up Contribution Limits at a Glance

Category 2025 2026
401(k) standard deferral limit $23,500 $24,500
Catch-up (age 50+) $7,500 $8,000
"Super" catch-up (ages 60–63) $11,250 $11,250
Total max (under 50) $23,500 $24,500
Total max (age 50+) $31,000 $32,500
Total max (ages 60–63) $34,750 $35,750

The "Super" Catch-Up — Ages 60 to 63

SECURE 2.0 also introduced an enhanced catch-up for employees aged 60, 61, 62, or 63. These individuals can contribute up to $11,250 in catch-up contributions (instead of $8,000), bringing their total possible deferral to $35,750 in 2026.

Key details:

What This Means for Employers

Three things you need to do:

  1. Check your plan document — Does your 401(k) plan offer a Roth contribution option? If not, you need to add one before January 1, 2026, or your high-earning employees lose the ability to make any catch-up contributions.
  2. Identify your high-income earners — Review 2025 W-2 Box 3 (FICA wages) to determine which employees earned over $150,000. These employees must be flagged in your payroll system for mandatory Roth catch-ups.
  3. Update payroll systems — Your payroll provider needs to route catch-up contributions correctly:
    • Employees earning ≤ $150,000 → Can choose pre-tax OR Roth catch-up
    • Employees earning > $150,000 → Must be Roth catch-up only

How iSolved Handles It

As a BlueWave HR client using iSolved People Cloud, the heavy lifting is done for you:

FAQ

Does this apply to IRA catch-up contributions?

No. The mandatory Roth rule only applies to employer-sponsored plans (401(k), 403(b), 457(b)). IRA catch-up contributions are unaffected.

What if an employee earned $150,000+ from another employer but less from us?

The threshold is based on FICA wages from the employer sponsoring the plan only. If they earned $140,000 from you, they're not subject to the mandatory Roth rule in your plan — even if their total household income is much higher.

What if our plan doesn't offer Roth 401(k)?

Your high-income employees (age 50+) will not be able to make any catch-up contributions at all. This could be a significant retention issue for senior employees. Adding a Roth option should be a priority before year-end.

What is the super catch-up contribution for ages 60-63?

Under SECURE 2.0, employees aged 60, 61, 62, or 63 can make enhanced catch-up contributions of up to $11,250 in 2026 (instead of the standard $8,000 for age 50+). This brings their total possible 401(k) deferral to $35,750. Once they turn 64, they revert to the standard catch-up limit.

Need Help Updating Your 401(k) Plan?

BlueWave HR helps businesses navigate retirement plan compliance through iSolved — from catch-up contribution tracking to automated Roth election routing. Let us handle the complexity so you don't have to.

Talk to a Benefits Expert
401(k) SECURE 2.0 Catch-Up Contributions Roth 401(k) High Income Earner Benefits 2026
BW

BlueWave HR provides full-service payroll and human capital management for small and mid-size businesses, powered by iSolved People Cloud. With offices in Canton, GA and Fort Lauderdale, FL, we deliver enterprise-grade technology with the personal touch of a local team.

🔔 Compliance Alerts

What do you need to stay on top of?

We track compliance changes, tax updates, and industry rules for our clients. When something changes in your world, we'll send you a heads up.

Pick your topics:

You'll only hear from us when something changes in your selected topics.
No sales emails. No weekly digests. Unsubscribe with one click.

You're in the loop!

We'll only reach out when something changes in your selected topics. No spam — that's a promise.