What is the Wage Threshold Requiring Roth Catch-Ups in 2026?

Q: In your Ask the Experts column in October you indicated that we did not yet know what the final 2025 FICA wage threshold would be for determining whether catch-up contributions must be made as Roth in 2026. Do we know now?

Kimberly Boberg, Kelly Geloneck, Emily Gerard and David Levine, with Groom Law Group, and Michael A. Webb, senior financial adviser at CAPTRUST, answer:

A: Yes, but it was announced a bit later than the Experts anticipated in that October column due to the government shutdown. On November 13, 2025, the IRS issued Notice 2025-67, which disclosed all of the retirement plan indexed limits, for 2026. To address any potential confusion over whether the new indexed wage threshold would apply to 2025 wages or 2026 wages when determining mandatory Roth contributions (since the Notice generally applies to 2026 limits), the IRS was quite clear in its language in the Notice, as follows:

“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.”

Thus, the 2025 FICA wage threshold is $150,000, which will be used to determine whether catch-up contributions must be made as Roth in 2026. Plan sponsors now have less than two months to implement this new indexed wage threshold, as well as the remainder of the mandatory Roth catch-up provision of SECURE 2.0. 

NOTE: This feature is to provide general information only, does not constitute legal advice and cannot be used or substituted for legal or tax advice.

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