If you turned 50 by December 31 and your FICA-taxable wages last year with your current employer topped $150,000, the extra money you plan to catch up in your 401(k) this year is going into Roth. Whether you want it there or not. Whether your CPA planned for it or not.
The rule kicked in January 1, 2026. Half the year is gone. And if your plan sponsor is still catching up on the paperwork, you might be locked out of the catch-up entirely without knowing it.
Here is what changed. SECURE 2.0, the 2022 law, said high earners can no longer route catch-up contributions into a pretax 401(k). Congress wrote it to start in 2024. IRS gave plans a two-year administrative transition to build the plumbing. The final regulations landed with Notice 2025-67 last fall, and the rule went live this January (IRS). The threshold is now $150,000 in prior-year FICA wages, indexed up from the statutory $145,000.
The standard catch-up is $8,000 in 2026 for age 50 and up. If you turn 60, 61, 62, or 63 during the year, you get the “super catch-up” of $11,250 instead. All of it, if you cross the wage line, goes into Roth. Your regular $24,500 employee deferral can still be pretax or Roth, your call. The catch-up money can only be one thing.
Here is what they don’t tell you. Some employer plans still don’t have a Roth 401(k) option. Under the final rule, if your plan cannot route the catch-up to a Roth bucket, you cannot make the catch-up at all. Not pretax. Not Roth. Nothing. The plan is supposed to add Roth. “Supposed to” is doing a lot of work.
Do the math. Someone in the 32% federal bracket loses about $2,560 in current-year deduction on the $8,000 catch-up. On the $11,250 super catch-up, roughly $3,600. That is not gone money, though. It shifts. The Roth grows tax-free, and you owe no income tax on the withdrawal. If you expect your retirement rate to be lower than 32%, you gave up value. If you expect it to be higher, you came out ahead. Same rate in and out, you break even.
Verdict: not dumb, not the win the marketing suggests. Neutral for most, painful this year for high earners who were counting on the write-off.
Two moves this week. First, log into your 401(k) portal and confirm the plan offers Roth. If it does, check that your catch-up election is flagged Roth, not pretax. Most recordkeepers added a checkbox for this. Some let the election bounce quietly, and you find out at year-end. Second, if the plan does not offer Roth, email HR and ask when it is coming. Push. Being locked out of a shelter worth $8,000 to $11,250 for the rest of the year is real money.
If you were counting on the deduction to cut your marginal tax bill, look at a traditional IRA (if you are not phased out) and top up an HSA. Both still shave taxable income the old way.
The rule is permanent. This year is not a dry run. If you are anywhere near the threshold, check your plan today.
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