This guidance is intended for retirement plan sponsors, administrators, and fiduciaries who implemented the Roth catch-up contribution requirements under the SECURE Act 2.0 and related IRS regulations by January 1, 2026. With mandatory Roth treatment for catch-up contributions of participants whose FICA wages exceeded $150,000 in 2025 that took effect January 1, 2026, employers had to make choices, such as whether to require compliant affirmative elections versus using deemed Roth elections. To make these important compliance considerations, it is essential to understand both the technical rules and their practical application. Written by Maria T. Hurd, CPA, RPA, Retirement Plan Audit Services Practice Group member and Industry Expert, and shared from our industry specific blog, The Art of the Qualified Plan Audit, the following posts provide clear explanations, real-world compliance examples, and timely insights to help plan sponsors and fiduciaries reduce compliance risk and ensure their retirement plans are administered accurately and effectively.
- Catch the Catch-Up Final Regulations Before They Catch You Off-Guard
- Roth Catch-Up Mandate Compliance and Deemed Election Examples
Your payroll provider likely sent you instructions on how to properly identify Roth-catchup eligible participants on your payroll and how they will help you identify when to switch contributions to Roth under your selected Deemed Election method, as applicable, but this subject can be confusing so please contact our Employee Benefit Plan Audit Practice Group if you have any questions.
