High-earners in multiemployer retirement plans face a delayed shift to after-tax catch-up contributions

Participants age 50 or older in certain retirement plans whose prior-year Social Security wages exceed $150,000 in 2026 will be required to make catch-up contributions on a Roth, after-tax basis. This requirement applies to participants eligible for catch-up contributions in plans that permit them.

The Treasury and IRS finalized these regulations under the SECURE 2.0 Act. Those whose prior-year wages do not exceed the threshold will continue to make catch-up contributions on a pre-tax basis, if permitted by the plan.

Multiemployer plans, where multiple employers contribute to a single plan maintained via collective bargaining agreements, face a delayed implementation. These plans are treated as satisfying the requirement until the first calendar year beginning after the later of December 31, 2026, or the expiration of the last collective bargaining agreement in effect on November 17, 2025.

Once this relief ends, multiemployer plans must identify affected participants and administer Roth catch-up contributions across multiple employers and payroll systems.