We're finalizing additional resources for plan sponsor and participant use, including an impacted participant notification template, procedure template, and more. Efforts are also underway to update resources with IRS contribution limits and Provision 603 income threshold for 2026. New and updated materials will be added to this page through the end of the year.

Plan sponsor toolkit

Plan sponsor operational guide

Guide to uploading FICA wages

Whitepaper on final regulations released by the IRS

Checklist for plan sponsors and employers

7 benefits of adopting Roth today

Understanding SECURE 2.0

The 2026 Roth catch-up mandate and plan sponsor responsibilities (video)

Participant toolkit

Email template for participants

For plans with Roth | For plans without Roth

Newsletter content for participants

Participant FAQs one-pager

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Starting January 1, 2026, participants earning more than $150,000 (indexed) in FICA wages in the prior year must make all catch-up contributions as Roth contributions.
  • FICA wages include salary, tips, bonuses, commissions, and taxable fringe benefits (Box 3 on W-2).
  • FICA wages would be defined by reference to Social Security taxes and considered in the same year that they are considered for Social Security tax purposes.
  • Wage calculation is not prorated or aggregated across multiple employers. Eligibility is only met upon exceeding the $150,000 (indexed) threshold with the current employer.
  • Section 603 applies to age 50+ and the enhanced age 60-63 catch-up contribution types1
  • All Roth contributions made during the year count towards the Roth catch-up limit. This will be regardless of when they were contributed for purposes of determining if the mandatory Roth deferrals are satisfied.
  • Employers can deem a participant's pre-tax catch-up election to be a Roth catch-up election. Although they must provide the participant with an effective opportunity to stop catch-up contributions.
  • FICA Participation: An individual who did not have any FICA wages from the Employer from the prior calendar year would not be subject to the mandatory Roth catch-up and can maintain Pre-Tax Salary Contribution catch-up.
  • Optional Roth Offering: Employers are not mandated to offer Roth. If Roth is not offered, those participants earning greater than $150,000 (indexed) in the previous year cannot make any catch-up contributions.

[1] Under current proposed regulations, a participant who is eligible for Special 457(b) and 403(b) catch-ups may make such contributions on a pre-tax or Roth basis and are not required to make such contributions as Roth. Additionally, Section 603 has made changes to the Catch-Up coordination rules that may allow participants to utilize both Special Catch-Ups Contributions and Age 50+ Catch-Ups Contributions in the same year under certain circumstances. However, final guidance on this aspect of Section 603 is needed.

This material is not a recommendation to buy or sell a financial product or to adopt an investment strategy. Investors should discuss their specific situation with their financial professional.

FOR FINANCIAL PROFESSIONAL, CONSULTANT AND PLAN SPONSOR USE – NOT FOR DISTRIBUTION TO THE PUBLIC