Updated October 29, 2026. Quick answer: For catch-up contributions made in 2026 the Roth requirement applies to a participant whose 2025 FICA wages from the plan sponsor were above $150,000, up from $145,000, per IRS Notice 2025-67. Those catch-up contributions must then be designated Roth. The Treasury’s final regulations apply as written from 2027, and a good-faith standard governs before then; the 2027 side is on the Roth catch-up rule for 2027.
The rule in the statute
Section 414(v)(7)(A) says that for a participant “whose wages (as defined in section 3121(a)) for the preceding calendar year from the employer sponsoring the plan exceed $145,000, paragraph (1) shall apply only if any additional elective deferrals are designated Roth contributions”. In plain terms, catch-up contributions from a higher earner must go in as Roth (after-tax) contributions. The wages test looks at the year before.
The $145,000 is indexed. Section 414(v)(7)(E) says: “In the case of a year beginning after December 31, 2024, the Secretary shall adjust annually the $145,000 amount in subparagraph (A) for increases in the cost-of-living at the same time and in the same manner as adjustments under 415(d); except that the base period taken into account shall be the calendar quarter beginning July 1, 2023, and any increase under this subparagraph which is not a multiple of $5,000 shall be rounded to the next lower multiple of $5,000.”
The 2026 threshold
The IRS Notice says “The Roth catch-up wage threshold for 2025, which under section 414(v)(7)(A) is used to determine whether an individual’s catch-up contributions to an applicable employer plan (other than a plan described in section 408(k) or (p)) for 2026 must be designated as Roth contributions, is increased from $145,000 to $150,000.” That sentence also shows SEP and SIMPLE plans are outside the rule.
| FICA wage year tested | Catch-up year affected | Roth catch-up wage threshold | Change | Source |
|---|---|---|---|---|
| Statute base amount | Not a year | $145,000 | Section 414(v)(7)(A) | |
| 2025 | 2026 | $150,000 | +$5,000 from the $145,000 base (computed) | IRS Notice 2025-67 |
When the regulations apply
The Treasury’s final regulations were published in Internal Revenue Bulletin 2025-40. On timing: “For a plan that is not maintained pursuant to a collective bargaining agreement and not a governmental plan within the meaning of section 414(d), §1.414(v)-2 applies with respect to contributions in taxable years beginning after December 31, 2026.” Collective bargaining and governmental plans have later dates in the same section. Before the applicable date, “a reasonable, good faith interpretation standard applies with respect to the statutory provisions reflected in the final regulations.” So for 2026 the statute and the $150,000 threshold are in force and the plan follows a good-faith reading of them. A separate page covers why the old transition relief is over: the 2026 Roth catch-up requirement.
Who the wages test looks at
The test uses wages from the employer sponsoring the plan, not your total income. A self-employed owner or a partner with no FICA wages from the plan sponsor has nothing to test, which is covered on Roth catch-up when you have no FICA wages. The catch-up amounts themselves are on the 401(k) catch-up limits for 2026 and the super catch-up for ages 60 to 63.
Common mistakes
- Testing total income. The test is FICA wages from the sponsoring employer for the prior year, here 2025.
- Using $145,000 for 2026 catch-ups. That is the statute’s base and the earlier figure; the Notice raised it to $150,000.
- Treating 2026 as a year the rule does not reach because the regulations apply from 2027. The statute applies, and the regulations’ date governs the detailed rules.
Related: the 2026 Roth catch-up requirement, the 401(k) catch-up limits for 2026, Roth catch-up with no FICA wages, and the Roth catch-up rule for 2027.
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Answer againSources
- Internal Revenue Service, Notice 2025-67, 2026 Amounts Relating to Retirement Plans and IRAs, as Adjusted for Changes in Cost-of-Living: www.irs.gov
- 26 U.S.C. 414, Definitions and special rules (U.S. Code, 2024 edition, U.S. Government Publishing Office): www.govinfo.gov
- Internal Revenue Bulletin 2025-40 (September 29, 2025), final regulations on catch-up contributions (T.D. 10033 text, 26 CFR 1.414(v)-2): www.irs.gov
Read from the primary documents linked above on October 29, 2026. General information, not tax advice. Your own facts decide the outcome, and a preparer or the IRS itself is the right place to confirm anything consequential.