A Change to 401(k) Catch-up Contributions

Dec 12, 2023

The SECURE 2.0 Act has sparked retirement confusion and concerns. 

Retirement planning has become a puzzle of intricate legislation, and the recent changes brought about by the SECURE 2.0 Act have only added more complexity. While some alterations aim to enhance the retirement landscape, others have sparked confusion and concern, especially regarding catch-up contributions for higher-income earners in 401(k) plans.

Set to take effect in 2026, the new rules have left many scratching their heads, particularly those looking for clarity on their financial future.


SECURE 2.0 and Catch-Up Contributions

The SECURE 2.0 Act brought significant modifications to retirement account rules, with some changes already in effect. However, the adjustments to catch-up contributions for 401(k) plans have been met with uncertainty. For older adults seeking to optimize their retirement savings, understanding these changes is crucial, as they play a pivotal role in long-term financial planning.


Roth Basis for Catch-Up Contributions

One of the central concerns arising from SECURE 2.0 revolves around the alteration in the rules governing catch-up contributions for higher-income earners in 401(k) plans. Traditionally, catch-up contributions allowed individuals aged 50 and above to contribute additional funds to their retirement accounts, providing a last-minute opportunity to bolster savings.

However, the catch is that, under the new rules, catch-up contributions for those earning $145,000 or more in the previous year must be made on a Roth basis. Unlike traditional 401(k) contributions, making catch-up contributions on a Roth basis involves utilizing after-tax money. This means paying taxes on these contributions during the years when individuals typically earn more, as opposed to deferring taxes until retirement.


The Tax Dilemma

The dilemma lies in the tax implications of this shift. While traditional 401(k) contributions offer the advantage of deferring taxes until retirement, the SECURE 2.0 changes require higher-income earners to pay taxes on catch-up contributions upfront. This approach could be disadvantageous for those who anticipate being in a lower tax bracket during retirement.

Additionally, catch-up contributions made on a Roth basis do not grant tax deductions, a benefit enjoyed by individuals contributing to traditional 401(k) accounts. Despite this, the silver lining is the potential for tax-free withdrawals in retirement, offering a degree of flexibility in managing tax liabilities during the post-working years.


Income Thresholds and Exclusions

It’s important to note that the SECURE 2.0 Roth catch-up contribution rule applies exclusively to taxpayers earning $145,000 or more in a tax year.

Those with an income of $144,999 or less are exempt from this particular provision, providing some relief for those on the cusp of the income threshold.


Seek Advice

As the SECURE 2.0 Act ushers in changes to retirement planning, the adjustments to catch-up contributions for higher-income earners in 401(k) plans have sparked both confusion and concern. The requirement to make catch-up contributions on a Roth basis introduces a new layer of complexity, forcing individuals to navigate the trade-off between immediate tax implications and potential tax-free withdrawals in retirement.

For those affected, seeking advice from financial professionals and staying informed about the evolving landscape of retirement regulations is essential for making well-informed decisions in the ever-changing realm of retirement planning.


Updates of Interest in the Latest IRS Notice 2023-62

1.      Postponement of Roth Catch-Up Rule: The IRS has delayed the effective date of the rule requiring higher-paid older employees’ catch-up contributions to be made on a Roth basis. Initially set for January 1, 2024, this mandate is now postponed to January 1, 2026. This extension allows plans to continue accepting pre-tax catch-up contributions from all employees until the end of 2025.

2.      Parameters of the Rule: The Roth catch-up mandate will apply only to employees whose “wages” from the employer exceed a specified threshold in the preceding year. For instance, if the rule were effective in 2024, the wage threshold for 2023 would have been $145,000. It’s important to note that this does not apply to self-employed individuals with self-employment income, as the IRS defines “wages” specifically as those subject to FICA (reported in Box 3 of W-2 forms).

3.      Multiple Employer Plans: In situations where a 401(k) plan is sponsored by more than one employer, an employee’s wages from different sponsoring employers are not aggregated for the threshold determination. Each employer’s wages are considered separately.

4.      Guidance for Plans Without Roth Options: The IRS is currently seeking public comments to decide the course of action for plans that do not offer Roth. This decision will determine whether these plans should limit catch-up contributions to lower-paid employees or eliminate them altogether.



To see how this change may affect you and your plan, reach out to our team at [email protected].  

The information provided here is accurate as of 12/13/2023. However, given the rapid pace of changes in tax regulations and guidelines, please be aware that this information is always subject to modification. We are committed to keeping you informed about any pertinent updates to ensure you have access to the most current and relevant details.

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