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Understanding new Roth 401(k) catch-up rules

Key takeaways

  • Starting in 2026 higher earners making catch-up contributions to a 401(k) will have to make these contributions to a Roth 401(k).
  • Consider fully funding your 401(k) and taking advantage of any employer match that may be available.
  • In addition to a 401(k), you may be able to contribute to other tax-advantaged accounts, such as a health savings account.
  • Nondeductible contributions to a traditional IRA and backdoor Roth IRA conversions may also be considerations.

Starting in 2026 some important changes are coming to the way higher earners who make catch-up contributions to their workplace retirement plans can fund their accounts.

The change, which stems from the SECURE 2.0 Act of 2022, is part of a shift in recent retirement and tax legislation that emphasizes contributions to Roth accounts, which can have important implications for your retirement planning.

What is the new 401(k) catch-up contribution rule?

If you’re 50 or older and your Federal Insurance Contributions Act (FICA)-taxable earnings are $150,000 or more, any catch-up contributions to your 401(k) will have to be made to a Roth 401(k) with after-tax dollars. That means you’ll lose out on the upfront tax deduction you may have had previously, but you can potentially benefit from the advantages Roths can offer, including tax-free earnings and withdrawals, as long as you meet the 5-year aging rule for the plan.1

401(k) contribution and catch-up amounts

401(k) contributions 2025 2026
Contribution amount $23,500 $24,500
50+ catch-up $7,500 $8,000
60-63 catch-up* $11,250 $11,250
Catch-up contributions must be to a Roth Does not apply In effect for those with FICA earnings above $150,000 in 2025.

*If the plan allows

The rule change is permanent, and it is also based on the prior year W-2 form from the employer sponsoring the plan, which means if you earned $150,000 or more for tax year 2025, the change applies to you for the 2026 tax year. Note: If your plan does not offer a Roth 401(k) option, you won’t be able to make catch-up contributions. The 1-year lookback applies to subsequent years as well.

Good to know: If your FICA earnings were under $150,000, you will be unaffected by the rule change and can continue making catch-up contributions to your 401(k), either to a traditional account or to a Roth 401(k), if your plan administrator offers one.

If the change in catch-up contributions is causing you to rethink your retirement saving strategy, here are 5 financial moves to consider that could help keep you on track.

1. Consider a health savings account (HSA). In addition to a 401(k), you may be able to contribute to other tax-advantaged accounts. For example, if you’re enrolled in an HSA-eligible health plan, an HSA can help you pay for qualified medical expenses with pre-tax income while also offering potential tax savings that can support retirement goals.

The money you contribute isn't subject to federal income tax, earnings accumulate tax-free, and withdrawals are not subject to federal income tax when they’re used for qualified medical expenses.2 Also, contributions through employer payroll deduction are not subject to FICA and the Federal Unemployment Tax Act (FUTA) taxes.

Starting at age 65, you can use savings in your HSA to pay for just about anything, penalty-free. One catch, however, is that you have to pay income tax on HSA dollars used for non-medical expenses, similar to withdrawals from a traditional IRA, even after age 65.

If you are eligible to contribute to an HSA, contribution limits are $4,400 for self-only coverage and $8,750 for family coverage for 2026. That's up from $4,300 for self-only coverage and $8,550 for family coverage in 2025. If you and your spouse (if applicable) are both age 55 or over, not enrolled in Medicare, and otherwise eligible, you each can make a $1,000 HSA catch-up contribution in 2026, but you must do so in separate HSAs.

2. Max out your regular contributions. For 2026, the maximum contribution amount for all 401(k) savers regardless of age increases to $24,500. That means you can put an additional $1,000 away in tax-advantaged accounts. Your contributions would be separate from any matching funds your employer may contribute, and do not count toward your own contribution limit for the year. There is an aggregate employee and employer contribution limit. That limit is $72,000 in 2026.

3. Consider partial contributions to a Roth IRA. If you’re looking for additional Roth options, you may be able to contribute to a Roth IRA. Single filers with modified adjusted gross income (MAGI) between $150,000 and $165,000 in 2025, and $153,000 and $168,000 in 2026 can make partial contributions to a Roth IRA. The same is true for couples who are married filing jointly with MAGI between $236,000 and $246,000 in 2025 and $242,000 and $252,000 in 2026. Note: Single filers and those who are married filing jointly with MAGI above these amounts for tax years 2025 and 2026 can’t make contributions to a Roth IRA.

Contributions for prior tax years can be made up until the tax filing deadline of the current tax year. Both you and your spouse, if applicable, can make independent contributions. If you think the income ranges are close to the mandatory Roth cutoff point of $150,000, note that FICA earnings differ from MAGI, which is calculated using your adjusted gross income (AGI) and may be lower than FICA earnings due to certain deductions and adjustments.

Also note that contributions to a Roth IRA and a Roth 401(k) must each meet a separate 5-year aging rule to avoid taxes and penalties.

4. Think about contributing to a traditional IRA. Regardless of whether you’re covered by a workplace retirement plan, you can still make nondeductible contributions to a traditional IRA up to the annual contribution limit, which is $7,000 for tax-year 2025 and $7,500 for tax-year 2026. Individuals who are age 50 and older can make catch-up contributions of $1,000 and $1,100 in those respective years. Nondeductible contributions won’t lower your tax bill, but funds in the account can grow tax-deferred until you withdraw them in retirement. (That’s different from a standard brokerage account where earnings and dividends could be taxed annually.) Also, you could convert those funds to a Roth IRA using a backdoor conversion later.

5. Convert traditional IRA funds to a Roth IRA. A backdoor Roth IRA conversion is a way of moving money into a Roth IRA by making nondeductible contributions—or contributions on which you do not take a tax deduction—to a traditional IRA and then converting those funds into a Roth IRA. It's different from a standard Roth conversion, which is the transfer of tax-deductible contributions in a traditional IRA to a Roth IRA. While a standard Roth conversion would be fully taxable to you in the year of conversion, a backdoor Roth conversion could have some complex tax considerations, especially if any IRAs you own contain tax-deferred funds, which are considered in aggregate for tax purposes with a Roth conversion. Converted balances to a Roth must also meet a separate 5-year aging rule to avoid penalties on withdrawals.

While no one likes to lose a tax benefit or deduction, with some additional planning you can minimize its impact. Remember, it’s always best to consult with a tax or financial professional about your retirement savings goals so you can come up with a plan that best suits your needs.

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1. For a distribution to be considered qualified, the 5-year aging requirement has to be satisfied, and you must be age 59½ or older or meet one of several exemptions (disability, qualified first-time home purchase, or death among them). 2. Contributions, earnings, and distributions are tax-free for federal tax purposes when used to pay for qualified medical expenses. Each state may decide to follow the federal tax guidelines for HSAs or establish its own. As of the publication date of this article, only California and New Jersey tax eligible contributions to HSAs. These states regard HSAs as regular taxable brokerage accounts, so residents have to declare any capital gains, interest, and dividends they receive to the state. New Hampshire and Tennessee tax earnings but not contributions. The triple tax advantage applies to state taxes as well, in most states.

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Fidelity does not provide legal or tax advice. The information herein is general and educational in nature and should not be considered legal or tax advice. Tax laws and regulations are complex and subject to change, which can materially impact investment results. Fidelity cannot guarantee that the information herein is accurate, complete, or timely. Fidelity makes no warranties with regard to such information or results obtained by its use, and disclaims any liability arising out of your use of, or any tax position taken in reliance on, such information. Consult an attorney or tax professional regarding your specific situation.

The information provided here is general in nature. It is not intended, nor should it be construed, as legal or tax advice. Because the administration of an HSA is a taxpayer responsibility, customers should be strongly encouraged to consult their tax advisor before opening an HSA. Customers are also encouraged to review information available from the Internal Revenue Service (IRS) for taxpayers, which can be found on the IRS Web site at www.IRS.gov. They can find IRS Publication 969, Health Savings Accounts and Other Tax-Favored Health Plans, and IRS Publication 502, Medical and Dental Expenses (including the Health Coverage Tax Credit),online, or you can call the IRS to request a copy of each at 800.829.3676.

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