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Roth catch-up contributions for highly paid individuals

Effective as of January 1, 2026

Plan sponsor toolkit

Use these resources to help you and your plan team navigate and implement the mandate.

Implementing the mandate

Operational support guide including an overview, definitions, and plan sponsor responsibilities.
Reference guide on how to upload FICA wage information for impacted participants.
Template to document practices and procedures for the 401(k) plan.
Template to document practices and procedures for the 403(b) plan.
Template to document practices and procedures for the 457(b) plan.

Learn more about the mandate and Roth

Plan sponsor responsibilities for the 2026 mandate.
Benefits bulletin whitepaper released by the IRS on SECURE 2.0's required Roth catch-ups.
Explore the 7 benefits of adopting Roth, including helping you and your participants stay compliant.

Participant toolkit

Nationwide will share information with participants through email and web content. This toolkit includes additional resources that you can share with participants through your internal channels.

Educate participants on the changes

Review a list of questions and answers about the contribution changes.
Discover options to keep yourself on track toward your retirement goals.
The latest update for high income participants making catch-up contributions.

Notify impacted participants of actions they should take

Email template for participant plans with Roth.
Email template for participant plans without Roth.
Sample template notice for highly paid individuals.

Key topics

Starting January 1, 2026, participants earning more than $150,000 (indexed) in FICA wages in the prior year must make all catch-up contributions as Roth contributions.

  • FICA wages include salary, tips, bonuses, commissions, and taxable fringe benefits (Box 3 on W-2).
  • FICA wages would be defined by reference to Social Security taxes and considered in the same year that they are considered for Social Security tax purposes.
  • Wage calculation is not prorated or aggregated across multiple employers. Eligibility is only met upon exceeding the $150,000 (indexed) threshold with the current employer.
  • Section 603 applies to age 50+ and the enhanced age 60-63 catch-up contribution types1
  • All Roth contributions made during the year count towards the Roth catch-up limit. This will be regardless of when they were contributed for purposes of determining if the mandatory Roth deferrals are satisfied.
  • Employers can deem a participant's pre-tax catch-up election to be a Roth catch-up election. Although they must provide the participant with an effective opportunity to stop catch-up contributions.
  • FICA Participation: An individual who did not have any FICA wages from the Employer from the prior calendar year would not be subject to the mandatory Roth catch-up and can maintain Pre-Tax Salary Contribution catch-up.
  • Optional Roth Offering: Employers are not mandated to offer Roth. If Roth is not offered, those participants earning greater than $150,000 (indexed) in the previous year cannot make any catch-up contributions.

[1] Under current proposed regulations, a participant who is eligible for Special 457(b) and 403(b) catch-ups may make such contributions on a pre-tax or Roth basis and are not required to make such contributions as Roth. Additionally, Section 603 has made changes to the Catch-Up coordination rules that may allow participants to utilize both Special Catch-Ups Contributions and Age 50+ Catch-Ups Contributions in the same year under certain circumstances. However, final guidance on this aspect of Section 603 is needed.

This material is not a recommendation to buy or sell a financial product or to adopt an investment strategy. Investors should discuss their specific situation with their financial professional.

FOR FINANCIAL PROFESSIONAL, CONSULTANT AND PLAN SPONSOR USE – NOT FOR DISTRIBUTION TO THE PUBLIC