SECURE 2.0 Catch-Up Compliance: What Plan Sponsors Must Do Before 2026
A practical checklist for ensuring your 401(k) plan is ready for mandatory Roth catch-ups and the optional super catch-up.
SECURE 2.0 made significant changes to 401(k) catch-up contribution rules, and the compliance deadlines are approaching fast. If your plan isn't ready by January 1, 2026, your high-earning employees (and possibly you, if you're a business owner) may lose the ability to make catch-up contributions entirely.
This guide provides a practical compliance checklist for plan sponsors, HR directors, and business owners to ensure your retirement plan is SECURE 2.0 ready.
If your plan does not offer Roth contributions, employees who earned over $150,000 in 2025 will be unable to make ANY catch-up contributions in 2026.
This includes business owners. Failing to add a Roth feature could eliminate your own catch-up contribution opportunity.
Key Deadlines at a Glance
Important distinction: Operational compliance comes first. You must follow the new rules starting January 1, 2026, even though formal plan amendments aren't due until later. The IRS expects "good faith" compliance with the statutory requirements while the final regulations phase in.
Compliance Checklist: Actions to Take Now
1. Confirm Your Plan Offers Roth Contributions
This is the most critical item. Starting in 2026, participants who earned more than $150,000 in the prior year (based on W-2 Box 3) must make all catch-up contributions as designated Roth contributions.
- Check your plan document: Does it currently permit designated Roth contributions?
- If NO: Contact your recordkeeper immediately to add the Roth feature before January 1, 2026
- If YES: Confirm with your recordkeeper that systems are ready for mandatory Roth catch-ups
2. Coordinate with Payroll
Payroll plays a critical role in determining which employees are subject to the mandatory Roth catch-up requirement. Specifically, payroll must:
- Identify employees whose prior-year W-2 Box 3 (FICA wages) exceeded $150,000
- Flag these "high-paid individuals" (HPIs) to the recordkeeper before the first payroll of the year
- Route catch-up contributions for HPIs to Roth, not pre-tax
- Establish a process to monitor mid-year when employees hit the standard deferral limit ($24,500 in 2026) and "flip" additional contributions to Roth catch-ups
3. Decide on Deemed Roth Election vs. Separate Election
The final regulations allow two approaches for administering Roth catch-ups:
- Decide which approach your plan will use (most advisors recommend deemed election for ease of administration)
- If using deemed election: Ensure participants have an effective opt-out opportunity
4. Decide Whether to Offer the Super Catch-Up (Ages 60-63)
Unlike the mandatory Roth requirement, the enhanced catch-up limit for ages 60-63 is optional. Plans can choose whether to offer the higher limit ($11,250 for 2025-2026 vs. $8,000 standard).
- Determine whether to adopt the super catch-up
- If you're part of a controlled group: Coordinate across all entities (if one plan adopts, all must under universal availability rules)
- Notify your recordkeeper of your decision
5. Update Participant Communications
Employees need to understand how these changes affect them, especially high earners who will see their catch-ups automatically converted to Roth.
- Send targeted communication to employees age 50+ explaining the changes
- Specifically notify employees near or above the $150,000 threshold about mandatory Roth treatment
- If offering super catch-up: Communicate the enhanced limit to employees ages 60-63
- Update Summary Plan Description (SPD) when plan amendments are adopted
6. Adopt Plan Amendments (By December 31, 2026)
While operational compliance must begin January 1, 2026, you have until December 31, 2026 to formally amend your plan document. The amendment should address:
- Mandatory Roth treatment of catch-up contributions for high-paid individuals
- Whether the plan offers the age 60-63 super catch-up (if yes, retroactive to 2025)
- The election approach (deemed vs. separate)
- Any aggregation rules for controlled groups
Special Situations
Controlled Groups and Affiliated Employers
If your company is part of a controlled group, be aware that certain decisions may need to be coordinated across entities:
- Super catch-up: If one plan in the controlled group adopts the age 60-63 super catch-up, all plans in the group must offer it to avoid violating universal availability rules.
- HPI determination: The final regulations permit (but don't require) aggregation of wages across related employers when determining the $150,000 threshold. Decide whether to aggregate and document your approach.
Business Owners
If you're a business owner who participates in your company's 401(k) and you earn over $150,000, you're directly affected by these rules. If your plan doesn't offer Roth, you won't be able to make catch-up contributions starting in 2026, and you'll miss out on $8,000-$11,250+ in annual tax-advantaged savings.
Frequently Asked Questions
The Bottom Line
SECURE 2.0's catch-up changes are not optional; they're mandatory for plans that offer catch-up contributions to high earners. The most critical step is ensuring your plan offers Roth contributions before January 1, 2026. Without that feature, affected employees lose their catch-up opportunity entirely.
Don't wait until December. Start the conversation with your recordkeeper, payroll provider, and plan advisor now to ensure a smooth transition.
Need Help Getting Your Plan SECURE 2.0 Ready?
Ivory Wealth Management specializes in retirement plan compliance.
Schedule a complimentary plan review to ensure you're ready for 2026.