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Ask the Experts September 23, 2025
When Do Providers Need to Be Ready for Mandatory Roth Catch-Up Contributions?
Experts from Groom Law Group and CAPTRUST answer questions concerning retirement plan administration and regulations.
Reported by PLANSPONSOR Staff
Q: I am starting to panic a bit, since it is just more than three months from the effective date of mandatory Roth catch-up contributions, and the recordkeeper for our retirement plans is nowhere near ready! I’m truly worried that we will not be able to implement the provision on time, and, even if we do, there will be errors. Can the Experts offer words of comfort? HELP!
Kimberly Boberg, Kelly Geloneck, Emily Gerard and David Levine, with Groom Law Group, and Michael A. Webb, senior financial adviser at CAPTRUST, answer:
A: We don’t know if the Experts’ words will be comforting, but we can say that you are not the only plan sponsor worried about the implementation of this challenging provision. For those who are not familiar, effective January 1, 2026, those individuals who earned more than $145,000 (indexed) in prior-year FICA wages from the employer sponsoring the plan may only make catch-up contributions on a Roth basis and may no longer make pre-tax catch-up contributions.
The IRS did release final catch-up regulations on September 15, 2025, that might provide some comfort. Though the mandatory Roth catch-up provision remains effective on January 1, 2026, the effective date of the final regulations was delayed until tax years beginning after December 31, 2026 (with a later date for governmental and collectively bargained plans). This will give plan sponsors some time to figure out what they are doing for 2026 and going forward, without the burden of having to follow specific regulations to the letter (only a reasonable, good-faith interpretation is required for 2026).
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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