High Earners Roth Catch-up Provision
- Jordan Cross
- 23 hours ago
- 1 min read
Beginning in 2026, a new rule has changed how Highly Paid Individuals (HPI) make catch-up contributions. Workers age 50 or older who earned more than $150,000 in FICA Box 5 wages in 2025 must make their 2026 catch-up contributions as Roth, not pre-tax. Regular deferrals do not change.
While Employers can consider which approach best matches their systems, the level of complexity they want to manage, and how the strategy aligns with their broader company goals and benefits philosophy, as we communicated with clients in winter 2025, CrossPlans believes opting in via Deemed Election is the most administratively feasible election and process for most Plans.
This guide breaks down the rule, the choices you can make, and key points to consider as you prepare your plan for 2026.
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