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SECURE 2.0 Updates

What’s changing

Starting in 2026, new IRS rules will require certain participants to make catch-up contributions as Roth (post-tax) contributions. If you’re age 50 or older in 2026 and made over $150,000 in FICA wages in 2025 (and in any year after that), any catch-up contributions you make must be made as Roth contributions.

This is part of the SECURE 2.0 law of 2022 and applies to all retirement plans.

What’s staying the same

Regular employee contributions – up to the 2025 IRS limit of $23,500 – can still be made on either a pre-tax or Roth basis.

However this change applies only to catch-up contributions, which in 2025 are:

  • $7,500 for those 50 or older

  • $11,250 for those age 60-63

Who will be affected?

You’ll need to make catch-up contributions as Roth if you:

  • Are age 50 or older, and

  • Earned more than $150,000 in FICA wages in the prior year at your current employer, and

  • Want to make catch-contributions above the standard IRS limit.

Catch-up contributions allow participants age 50 and older to make additional contributions from their paycheck to their retirement account above the standard IRS limit for that year. The IRS limit for elective deferrals and for catch-up contributions changes each year.

Learn more about contribution limits.

Who will not be affected?

This does not apply to you if you:

  • Are clergy earning SECA wages (not FICA), or

  • Earned less than $150,000 in the prior year

  • Earned at least $150,000 in the prior year, but since started working for a new employer

If you’re unsure whether your wages are FICA or SECA, check with your employer or a tax advisor.

What are the benefits of Roth?

Roth post-tax contributions are made after taxes, but your qualified withdrawals in retirement will be federal tax-free. Over time, that can make a meaningful difference in your long-term savings.

Even making a small Roth contribution today – as little as a dollar – can be helpful because Roth withdrawals require a five-year waiting period. If you plan to retire in the next few years, making a post-tax contribution now starts that clock and gives you access to tax-free income sooner in retirement.

Review our Pre-Tax vs. Roth (Post-Tax) Contributions document for more information.

Next steps

  1. Check your contributions. See if you’re making catch-up contributions from your paycheck (those above the 2025 IRS limit of $23,500)

  2. Talk to your employer. If you meet the income threshold, make sure your employer is prepared to make any catch-up contributions on a Roth post-tax basis.

  3. Start now. Making even a small Roth contribution now starts your five-year clock for future federal tax-free withdrawals.

Get guidance. Contact us or speak to your employer or a tax advisor if you have questions.

Post-tax withdrawals are federal tax-free if:

  • You are at least 59.5 years old, and
  • You’ve had your account for at least five years, beginning January 1 of the year you made your first Roth contribution.

Start allowing employees to make Roth contributions today for their standard elective deferrals (if you don’t already).

Learn more.

Questions? We’re here to help.

Contact our Employer Services Team:

Robert Perry
Director of Participant and Employer Services
646.884.9890
rperry@rpb.org

Alyce Gunn
Chief Financial Officer
646.884.9888
agunn@rpb.org

Effective 2025 for participants age 60 - 63

Super catch-up contributions. Starting in 2025, participants who are between age 60 and 63 by the end of the calendar year will be able to make catch-up contributions up to 150% more than the standard catch-up amount. The standard catch-up limit for people age 50 and older is currently $7,500.

Check with your payroll provider to make sure they are set up to process the new age 60-63 catch-up limit.

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