• Skip to primary navigation
  • Skip to main content

HRMorning

  • FREE RESOURCES
  • PREMIUM CONTENT
  • HR DEEP DIVES
  • PODCASTS
    • VOICES OF HR
    • WOMEN’S LEADERSHIP TODAY
  • LOGIN
  • SIGN UP FREE
  • Employment Law
  • Benefits
  • Recruiting
  • HR Technology
  • Payroll
  • Management
  • Women’s Leadership
  • More
    • Talent Management
    • Performance Management
    • Leadership & Strategy
    • Compensation
    • Policy & Procedures
    • Wellness
    • Staff Departure
    • HR Career & Self-Care
    • Health Care
    • Retirement Plans
PAY Logo
  • Compensation
  • Payroll

IRS Explains When Roth Catch-Up Contributions Are Required

Jennifer Weiss
By: Jennifer Weiss
  • Share on

About the Author

Jennifer keeps readers current on Payroll news, covering topics such as employment taxes, fringe benefits and the Fair Labor Standards Act. She brings over 20 years of experience to the HRMorning staff.

Show Less
Last Updated: October 2, 2025
2 minute engagement
irs changes

Ever since the Secure 2.0 Act laid out changes for workplace retirement plans, employers have been waiting for final regs from the IRS.

Now, the regs are here.

The 2022 law established new requirements, impacting 401(k), 403(b) and 457(b) plans that allow participants who are age 50 or older to make catch-up contributions.

Specifically, the Secure 2.0 Act said catch-up contributions made by participants who exceed a certain wage threshold will need to be designated as after-tax Roth contributions.

The final regs, issued September 16, 2025, provide needed details and generally pertain to tax years beginning after December 31, 2026.

The final regs explain that the Roth catch-up wage threshold is $145,000 (to be adjusted for inflation). If in one year, an employee earns more than that amount in FICA wages, any catch-up contributions made in the next year will be subject to taxes.

One way the final regs differ from the proposed regs: To determine if a participant has exceeded the wage threshold, the plan administrator can aggregate wages received from certain separate common law employers.

Reporting Corrections to IRS

Employers that fail to comply with the Roth catch-up requirement can use one of two methods to correct the problem and report the changes to the IRS. They are:

  • Form W–2 Correction Method. You’d transfer the elective deferral from the pre-tax account to the Roth account and report the contribution accordingly on Form W–2 for the deferral year.
  • In-Plan Roth Rollover Correction Method. You’d roll over the elective deferral from the pre-tax account to the Roth account, and the rollover would be reported on Form 1099–R.

Super Catch-Up Contributions

The Secure 2.0 Act also permitted so-called super catch-up contributions. These are higher contribution limits for employees who are closer to retirement age — i.e., those who are ages 60, 61, 62 and 63.

The allowed amount is 150% of the regular catch-up contribution amount.

For example, if the normal catch-up max is $7,500, for the eligible participants, it’d be $11,250.

The IRS final regs stated that if a plan document references the catch-up contribution limit under Internal Revenue Code Sec. 414(v), the plan’s terms should make it clear whether that includes super catch-up contributions.

Filed under
PAY Logo
  • Compensation
  • Payroll
  • Share on

Get the HRMorning Newsletter

With HRMorning arriving in your inbox, you will never miss critical stories on labor laws, benefits, retention and onboarding strategies.

  • This field is for validation purposes and should be left unchanged.
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form
  • This field is hidden when viewing the form

Free Training & Resources

White Papers

Making the Case: Proving ROI of Employee Recognition Programs

Provided by Inspirus

Webinars

Build and Scale a Fully Remote Onboarding Process that Actually Works

White Papers

A Year of Employee Appreciation Ideas

Provided by Inspirus

White Papers

Demystifying HSAs: A new study reveals the myths around HSAs

Provided by Incomm

SPONSORED CONTENT

HR Technology

sponsored content
The Best AI Software for HR Automation

Courtesy of G-P

Talent Management

sponsored content
Powerful Employee Retention Strategies for 2025: How to Keep Your Best People

Courtesy of PEOPLEGURU

Benefits

Health Care

Wellness

sponsored content
Proven Results: 5 Ways Teladoc Health Chronic Condition Management Transforms HR Outcomes

Courtesy of TELADOC HEALTH

Further Reading

  • Benefits
  • Payroll
Uncashed Check? IRS Ruling on Retirement Plan Distributions

The IRS has explained how to handle taxes if a retirement plan participant doesn’t cash a distribution check and another check is issued....

  • Compensation
  • Payroll
State UI Tax: A Quick Look at Wage Base Changes for 2026

Wage bases for 2026 are rolling out. You can ensure you’re accurately withholding for state unemployment insurance (UI) tax. Here’s...

  • Employment Law
  • Payroll
Payroll Problems Lead to Proposed $162M Settlement in New York

A federal court has approved a proposed $162 million class action settlement between Public Partnerships LLC (PPL) and personal assistants ...

  • Compensation
Severance pay: Definition and guidance for HR professionals

Ever wonder about all the ins and outs of severance pay? If the answer is yes, you’re in the right place. What exactly is severance pa...

  • Compensation
  • Payroll
Payroll Alert: New Minimum Wage Rates Update July 1

Mid-year minimum wage increases catch more payroll teams off guard than January changes do. Several state, local and industry-specific mini...

  • Compensation
The Unintended Consequences of Pay Transparency: 3 Tips to Handle the Fallout

HR professionals have had to increase their vigilance to pay transparency in recent years. Between new laws and professional demands, HR...

Get the latest from HRMorning in your inbox PLUS immediately access 10 FREE HR guides.

I WANT MY FREE GUIDES
HR Morning Logo
  • Facebook
  • Linked In
  • ABOUT HRMORNING
  • ADVERTISE WITH US
  • WRITE FOR US
  • CONTACT
  • Employment Law
  • Benefits
  • Recruiting
  • Talent Management
  • Performance Management
  • HR Technology
  • Leadership & Strategy
  • Compensation
  • Policy & Procedures
  • Wellness
  • Staff Departure
  • HR Career & Self-Care
  • Health Care
  • Retirement Plans
  • DEI

HRMorning, part of the Rover Insights Network, provides the latest HR and employment law news for HR professionals in the trenches of small-to-medium-sized businesses. Rather than simply regurgitating the day's headlines, HRMorning delivers actionable insights, helping HR execs understand what HR trends mean to their business.

Powered By Rover Insights
Privacy Policy | Terms of Service
Copyright© 2026 Rover Insights
HRMorning Logo

WELCOME BACK!

Enter your username and password below to log in

Forget Your Username or Password?

Reset Password

Lost your password? Please enter your username or email address. You will receive a link to create a new password via email.

Log In

Why do we need your credit card for a free trial?

We ask for your credit card to allow your subscription to continue should you decide to keep your membership beyond the free trial period.  This prevents any interruption of content access.

Your card will not be charged at any point during your 21 day free trial
and you may cancel at any time during your free trial.

During your free trial, you can cancel at any time with a single click on your “Account” page.  It’s that easy.