A Roth is Really Special—But Know the Rules

For plan years beginning in 2026, higher-compensated participants (not highly compensated employees under Section 414(q)) in 401(k) plans and salary reduction 403(b) plans will not be allowed to make catch-up contributions on a pre-tax basis. But they will be permitted to make them to a designated Roth account up to the applicable catch-up limits. The restriction applies to individuals whose FICA wages for the preceding calendar year paid by the plan sponsor exceed $145,000 (to be indexed for inflation). It is anticipated that plans must have (or will need to add) a Roth feature to take advantage of the rule.  Another Roth rule is already effective. In and after 2024, plan sponsors of defined contribution plans can include an emergency savings account provision in their plans for non-highly compensated employees (NHCEs). This feature allows NHCEs, if they choose, to contribute up to $2,500 to an emergency subaccount, called a pension-linked emergency savings account (PLESA), but only on a Roth basis. So, get ready for the Roth!

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