Updated October 28, 2026. Quick answer: The final regulations on the Roth catch-up rule apply to contributions in taxable years beginning after December 31, 2026, so 2027 is the first year they apply as written for most plans; collective bargaining and governmental plans have later dates. Whether the rule reaches you in 2027 turns on your 2026 FICA wages from the employer sponsoring the plan, and the IRS has not announced the wage threshold for 2027 catch-up contributions. The threshold for 2026 catch-up contributions, tested on 2025 wages, is $150,000, per IRS Notice 2025-67. This page updates when the IRS publishes the 2027 figure.
More on the 2026 tax figures: the Roth catch-up rule for 2026.
What is not yet announced
As of October 28, 2026 the IRS has not published the Notice that sets the 2027 retirement plan limits; the 2026 version was Notice 2025-67. This page states only the 2026 figure, as a 2026 figure, and changes when the IRS publishes the 2027 Notice.
One thing to avoid: the final regulations contain worked examples that assume numbers for 2027. They are assumptions written for the examples, covered below, not IRS announcements.
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 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.
The threshold year by year
| 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 (computed) | IRS Notice 2025-67 |
| 2026 | 2027 | not yet announced | Awaiting the IRS Notice |
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.” The 2026 side of that story is on the 2026 Roth catch-up requirement.
The 2027 numbers in the regulation are assumptions
The regulation’s examples begin with a set of assumed facts: “Assume further that this section applies to contributions in taxable years beginning in 2027, the section 401(a)(30) limit on elective deferrals for 2027 is $25,000, the applicable dollar catch-up limit for 2027 that is applicable to each participant in the examples is $8,000, and the Roth catch-up wage threshold to be applied to 2026 FICA wages for determining applicability of the Roth catch-up requirement under section 414(v)(7)(A) for a taxable year beginning in 2027 is $155,000.” Those are inputs the Treasury chose to make the examples work. They are not the announced 2027 limits, and this page does not treat them as such. The announced figures will be in the IRS Notice for 2027.
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 figures and the super catch-up for ages 60 to 63.
Common mistakes
- Using $155,000 as the 2027 threshold because it appears in the regulation. It is an assumption in an example, not an IRS announcement.
- Testing total income. The test is FICA wages from the sponsoring employer for the prior year.
- Thinking the rule starts only in 2027 for everyone. The regulations apply from 2027, and before that a good faith standard applies; see the 2026 page.
Related: the 2026 Roth catch-up requirement, Roth catch-up when you have no FICA wages, the 401(k) catch-up figures, and the 2027 tax numbers.
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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 IRS and Treasury documents linked above on October 28, 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.