When Congress passed the SECURE 2.0 Act in late 2022, many of the headlines focused on immediate retirement plan enhancements. Less attention was given to provisions that were intentionally delayed. As we approach 2026, several of those changes are now coming into play, and they will affect both plan participants and plan sponsors in meaningful ways.
For plan years beginning after December 31, 2025, employers should be aware of updates related to catch-up contributions, new distribution flexibility for long-term care costs, and revised participant communication requirements. Below is a closer look at what’s changing and why it matters.
Roth Catch-Up Contributions for Higher-Income Employees and “Super” Catch-Up Contributions
Beginning in 2026, employees aged 50 and older who earned more than $150,000 in FICA wages (Box 3 of W-2) during the previous year (2025) will be required to make any catch-up contributions on a Roth (after-tax) basis, assuming the plan offers a Roth feature. This is a shift from prior rules, which allowed catch-up contributions to be made on a pre-tax basis.
While pretax and Roth contributions share the same IRS limits, the contributions differ. Pretax contributions are, as the language indicates, deferred from an employee’s pay before payroll taxes are calculated and therefore reduce taxable income. Paying taxes on these types of contributions is only deferred, and taxes are owed when the money is taken out of (or distributed from) the retirement account.
Roth contributions are deferred from an employee’s pay after taxes have been calculated and taken out; therefore, taxes on these contributions are paid upfront. When the time comes to withdraw this money from the employee’s retirement account, it is distributed tax-free.
Continuing for 2026, the “super” catch-up contribution is an option for participants between the ages of 60 and 63 to contribute $11,250 beyond the normal catch-up contribution limit of $8,000 for 2026. These contributions must also be made on a Roth basis starting in 2026.
Participants turning 60 during 2026 can take advantage of this increased catch-up contribution for 2026. Thus, even if the participant turns 60 on December 31, 2026, they are eligible for this “super” catch-up, although most of the “super” catch-up for 2026 was made while they were age 59. Conversely, if a participant turns 64 on December 31, 2026, they are not eligible for the “super” catch-up and may only contribute a maximum catch-up of $8,000 for 2026.
How much can employees contribute in 2026?
Type of Retirement Plan |
Age on December 31, 2026 |
2026 Annual Salary Deferral Contribution Limit |
2026 Catch-up Contribution Limit |
Total 2026 Deferral Limit |
| 401(k), 403(b), 457(b) | Under 50 | $24,500 | $0 | $24,500 |
| 401(k), 403(b), 457(b) | 50-59 | $24,500 | $8,000 | $32,500 |
| 401(k), 403(b), 457(b) | 60-63 | $24,500 | $11,250 | $35,750 |
| 401(k), 403(b), 457(b) | 64 and over | $24,500 | $8,000 | $32,500 |
Note: Refer to the Internal Revenue Service website for additional limits and other types of plans
For employees who also receive contributions from their employers and/or make after-tax contributions, the contribution limit is even higher:
401(k), 403(b), 457(b) Contribution Limit for 2026 |
Employee/Participant Contributions (Pretax and Roth) |
Employee PLUS Employer Contributions |
Catch-Up Contributions |
Contribution Limit Total |
| Under age 50 | $24,500 | $72,000 | N/A | $72,000 |
| Age 50-59 | $24,500 | $72,000 | $8,000 | $80,000 |
| Age 60-63 | $24,500 | $72,000 | $11,250 | $83,250 |
| Age 64 and over | $24,500 | $72,000 | $8,000 | $80,000 |
It’s also important to note the administrative impact: plans that do not offer Roth contributions will no longer be able to accept catch-up contributions at all for affected employees. As a result, plan sponsors may want to review whether adding a Roth option makes sense as an amended plan provision. Employers should also review their employee census data to ensure those approaching catch-up age and “super” catch-up age are aware of their catch-up contribution eligibility.
Penalty-Free Distributions for Long-Term Care Insurance Premiums
Another change in effect in 2026 allows retirement plans to permit distributions for the payment of qualified long-term care insurance premiums. These withdrawals are exempt from the 10% early-distribution penalty that would normally apply.
The annual distribution limit is capped at the lesser of:
- the amount of the premium,
- 10% of the participant’s vested account balance, or
- $2,500 (indexed for inflation).
While optional, this provision introduces added flexibility for participants planning for future health-care needs.
Annual Paper Benefit Statement Requirement
Starting with 2026 plan years, defined contribution plans will be required to provide participants with at least one paper benefit statement each year. This applies unless a participant has affirmatively opted to receive statements electronically only. Plan sponsors relying heavily on electronic delivery should confirm that opt-out elections are properly documented.
Although plans are required to comply with all required SECURE Act provisions immediately upon their effective dates, plan documents must be formally amended to comply with the SECURE Act by December 31, 2026.
If you have questions about how these SECURE 2.0 changes may affect your retirement plan or your personal savings strategy, please contact your WG advisor. Our team can help you evaluate the impact of these provisions and determine next steps based on your specific circumstances.
