FORTRESSTax Advisors
Insights

Analysis

2026 Retirement Limits Land: $24,500 Deferrals, the 60–63 Super Catch-Up, and the Roth Catch-Up Mandate

The IRS has set the 2026 retirement plan limits, and they come with a complication that ordinary cost-of-living tables do not capture. Beyond the higher deferral and catch-up amounts, two SECURE 2.0 features converge for high earners in 2026: the enhanced catch-up for those aged 60 to 63, and the new rule requiring high earners to make catch-up contributions on a Roth basis. With final regulations now issued, the high-earner deferral decision must be made before year-end — not in January.

Originally publishedNovember 20255 min readBusiness & Planning

The 2026 figures

In Notice 2025-67, issued November 13, 2025, the IRS announced the cost-of-living adjustments for retirement plans for 2026. The headline figures:

  • The elective deferral limit for 401(k), 403(b), and most 457(b) plans rises to $24,500, up from $23,500 in 2025.
  • The standard age-50 catch-up contribution rises to $8,000, up from $7,500.
  • The IRA contribution limit rises to $7,500, up from $7,000 — the first increase to the IRA limit since 2024 — with the age-50 IRA catch-up at $1,100.
  • The defined-contribution annual additions limit under § 415(c) is $72,000, and the compensation limit under § 401(a)(17) is $360,000.

These are useful but routine. The two provisions that require active decisions are the ones layered on top.

The super catch-up for ages 60 to 63

SECURE 2.0 created an enhanced "super catch-up" for participants who reach ages 60 through 63 during the year. For 2026, that amount is $11,250 — set at 150 percent of the regular catch-up — and it remains $11,250, unchanged from 2025. It applies to participants who attain age 60, 61, 62, or 63 during the year, and it is an optional feature that a plan must adopt for its participants to use.

For a saver in that four-year window whose plan offers the feature, the practical effect is a materially larger ceiling: the $24,500 base deferral plus the $11,250 super catch-up, rather than the standard $8,000 catch-up. The window is narrow by design — it applies only at ages 60 through 63 — so eligible participants and the plans that serve them should confirm the feature is available and set deferral elections to use it while it applies.

The Roth catch-up mandate, now final

The provision that changes the most for high earners is the requirement that their catch-up contributions be made on a Roth basis — and the final regulations putting it in force were issued September 15, 2025.

The rule, from SECURE 2.0, works as follows. A participant whose prior-year Social Security (FICA) wages from the employer sponsoring the plan exceeded an indexed threshold must make any catch-up contributions on a Roth — after-tax — basis, rather than pre-tax. This applies to 401(k), 403(b), and governmental 457(b) plans. The threshold figure carries a detail that is easy to get wrong: while the statute set a $145,000 base, Notice 2025-67 indexed it to $150,000 for 2026 determinations. And it is measured against the prior year's wages — so it is a participant's 2025 FICA wages from the plan-sponsoring employer that determine whether 2026 catch-up contributions must be Roth.

The effective-date structure has two layers, and conflating them is the most common error in coverage of this rule. The statutory mandate applies to taxable years beginning after December 31, 2025 — so it is in force January 1, 2026. The final regulations, however, generally apply for taxable years beginning after December 31, 2026, with plans permitted to comply for 2026 using a reasonable, good-faith interpretation of the statute. The accurate way to state it: the requirement is legally in force for 2026, with a good-faith compliance period during 2026 before the regulations formally bite in 2027.

Why the high-earner decision belongs in this year

The convergence of these features is what makes 2026 deferral planning a year-end-2025 task rather than a January one.

Consider a high earner aged 60 to 63 in 2026 whose 2025 FICA wages from the employer exceeded $150,000. That participant is potentially eligible for the largest possible deferral — the base plus the $11,250 super catch-up — and is simultaneously required to make the catch-up portion as Roth. Those two facts interact. A Roth catch-up is funded with after-tax dollars and does not reduce current taxable income the way a pre-tax catch-up would, which changes the cash-flow and tax picture of maximizing the contribution. A participant who assumed a pre-tax catch-up, and budgeted accordingly, may find the after-tax cost different from what they expected.

There is also an administrative dimension. For the Roth catch-up to function, the plan must offer a Roth contribution feature and the payroll system must apply the rule correctly — identifying affected high earners based on prior-year wages and routing their catch-up contributions to Roth. Plan sponsors operating under the good-faith standard for 2026 need those mechanics working before the first 2026 payroll, not after. Elections set in January, on the assumption that nothing changed, risk being incorrect for exactly the highest-paid participants.

The defensible course is to make the 2026 deferral decision now: confirm whether the super catch-up applies, determine whether the Roth catch-up mandate applies based on 2025 wages, and set elections — and plan administration — accordingly before the year turns.

Key takeaways

  • Notice 2025-67 (Nov. 13, 2025) set 2026 limits: $24,500 elective deferral, $8,000 age-50 catch-up, $7,500 IRA limit, $72,000 § 415(c) limit, and $360,000 § 401(a)(17) compensation limit.
  • The SECURE 2.0 super catch-up for ages 60–63 is $11,250 for 2026, unchanged from 2025, and is an optional plan feature.
  • Final regulations issued September 15, 2025 confirm the Roth catch-up mandate: high earners must make catch-up contributions on a Roth basis, with the threshold indexed to $150,000 of prior-year (2025) FICA wages for 2026.
  • The Roth catch-up requirement is legally in force for 2026 (good-faith compliance permitted, regulations formally applying in 2027), making the high-earner deferral decision a year-end-2025 task.

Frequently asked questions

What is the 401(k) contribution limit for 2026?

The elective deferral limit is $24,500 for 2026, up from $23,500 in 2025. The standard age-50 catch-up is $8,000, and the enhanced catch-up for ages 60 to 63 is $11,250 where the plan offers it.

Do I have to make my catch-up contributions as Roth?

You do if your prior-year FICA wages from the employer sponsoring the plan exceeded the indexed threshold, which is $150,000 of 2025 wages for 2026 catch-up contributions. The requirement is in force for 2026, with a good-faith compliance period before the regulations formally apply in 2027.

Who qualifies for the larger 60-to-63 catch-up?

Participants who attain age 60, 61, 62, or 63 during the year, in a plan that has adopted the optional super catch-up feature. For 2026 the enhanced amount is $11,250.

Bottom line

The 2026 limits are higher across the board, but the real planning lives in the convergence of the super catch-up and the now-final Roth catch-up mandate for high earners. Because a high earner's catch-up must be Roth — funded after-tax — and because plan administration must be ready, the deferral decision for 2026 should be made before year-end 2025, not deferred to the new year.

Start Here

Weighing a decision this touches?

If this development maps to your position, the next step is a focused conversation. We define the issue and the timeline before recommending scope.

Speak with a Fortress advisorMore on Business & Planning

We typically respond within one business day.