Mandatory Roth Catch-Up Calculator 2026

What SECURE Act 2.0 §603 Requires

Section 603 of the SECURE Act 2.0 (December 2022) requires that catch-up contributions to 401(k), 403(b), and governmental 457(b) plans be made on a Roth (after-tax) basis if the participant\'s FICA wages from the plan sponsor in the prior calendar year exceeded $145,000 (indexed for inflation). The threshold is $145,000 for 2024, $145,000 for 2025 (announced; OBBB did not modify), and is projected to reach approximately $150,000 for 2026 pending IRS confirmation. Originally effective for tax year 2024, the IRS provided a two-year administrative transition period in Notice 2023-62, deferring the requirement to 2026. The 2025 catch-up limit (age 50+) is $7,500; the 2026 limit is expected to remain $7,500 (indexed). SECURE 2.0 §109 also created a higher "super catch-up" of $11,250 for ages 60-63 starting 2025. Source: IRS Notice 2023-62.

How the FICA Wage Test Works

The test looks at FICA wages (Social Security and Medicare-taxable wages, Box 3/5 of the W-2) paid by the SAME employer sponsoring the plan in the prior calendar year. If you change jobs mid-year, the new employer\'s test resets — your prior-year wages with that new employer (typically zero in your first calendar year there) are below the threshold, exempting you. Self-employed individuals with no FICA wages from a 401(k) sponsor are exempt from §603 because they have no FICA wages from a plan sponsor — only earned income from self-employment. Government employees and church plan participants may have different applicable thresholds. The threshold is plan-by-plan, not aggregated — if you work for two employers each below $145,000 in FICA wages individually, neither plan\'s catch-up is forced to Roth even if combined wages exceed the threshold. Source: IRC §414(v)(7) (Cornell).

Tax Impact: Roth Catch-Up vs Pre-Tax Catch-Up

A $7,500 Roth catch-up contribution does not reduce current-year taxable income, costing approximately $2,400 more in federal tax for a worker in the 32% bracket. The benefit: tax-free growth and tax-free distributions in retirement, including no RMDs from Roth 401(k) starting 2024 (SECURE 2.0 §325). For high earners expecting their retirement bracket to be lower (early retirement, geographic move to no-income-tax state), pre-tax was typically better — losing this option costs real money. For high earners expecting their retirement bracket to be similar or higher (large traditional balances driving RMDs into 32%+ brackets in late 70s), the mandatory Roth catch-up is actually a benefit, locking in tax-free dollars. Source: IRS Cost-of-Living Adjustments for Retirement Items.

Workarounds for High Earners

If your plan does not yet offer a Roth 401(k) feature, the plan must add one before 2026 or you cannot make catch-up contributions at all under §603. Some plans may delay catch-up implementation until plan amendment is complete — verify with your plan sponsor. Alternative strategies for affected high earners: (1) Switch employers so the prior-year FICA wages with the new employer are below the threshold in your first year. (2) Make catch-up contributions in your spouse\'s 401(k) if their wages are below the threshold. (3) Consider after-tax 401(k) "mega backdoor Roth" contributions — separate from catch-up and not subject to §603. (4) For very high earners hitting the §415(c) total contribution limit of $70,000 (2025), the catch-up amount is on top — see our Mega Backdoor Roth Calculator. Last updated May 2026.