If you are over 50, earning well, and have been making catch-up contributions to your 401(k) as pre-tax dollars, that option closed on January 1, 2026. Catch-up contributions are still available — the amount did not shrink — but for higher earners they must now go in as Roth money, which means you pay the tax this year instead of deferring it.

This is Section 603 of the SECURE 2.0 Act. It was originally supposed to take effect in 2024, got pushed back through an IRS administrative transition period, and is now live. The Treasury and IRS issued final regulations on September 16, 2025, as Treasury Decision 10033, so the rules are settled rather than provisional.

Who Counts as a High Earner

The threshold is more specific than “high income,” and the specifics matter enormously.

For 2026 catch-up contributions, you are subject to the mandate if you received more than $150,000 in FICA wages during 2025 from the employer that sponsors your plan. The statutory figure in SECURE 2.0 is $145,000, but it is indexed for inflation, and $150,000 is the amount that applies to the 2025 look-back year.

Three details inside that sentence do real work:

It is prior-year wages, not current-year. Your 2026 treatment depends entirely on what your 2025 W-2 showed. If you got a large raise in January 2026 that pushed you over $150,000 for the first time, you are not affected in 2026 — you will be in 2027.

It is FICA wages specifically. This is the single most consequential detail, and it is where a lot of well-off women are surprised to find they are exempt. FICA wages are Social Security and Medicare wages — W-2 employment income. Income that is not FICA wages does not count toward the threshold at all. A woman who takes $400,000 as K-1 partnership income from her own practice, or as self-employment income, has no FICA wages from that arrangement and is not a high earner for this test, regardless of how much she made. Partners, sole proprietors, and many practice owners fall outside the mandate entirely.

It is per-employer. The wages are measured from the employer maintaining the plan. If you changed jobs mid-2025, the wages from your former employer generally do not aggregate with the new one for this purpose. The regulations permit — but do not require — aggregating wages across employers within a controlled group or under a common paymaster, so the answer for large multi-entity employers depends on how your specific plan is administered.

What You Can Actually Contribute in 2026

The dollar limits went up, which softens the change:

  • Elective deferral limit: $24,500
  • Age 50+ catch-up: $8,000, for a total of $32,500
  • Ages 60–63 catch-up: $11,250, for a total of $35,750

The age 60–63 “super catch-up” comes with three conditions worth knowing. It replaces the age-50 amount rather than stacking on top of it. It switches off at 64 — it is a four-year window, not a permanent upgrade. And it is offered at the employer’s option, so your plan may simply not have it.

One structural risk deserves a flag: if your employer’s plan does not offer a Roth option at all, it cannot accept a mandated Roth catch-up. In that situation high earners may find catch-up contributions unavailable rather than merely taxed differently. If you are not certain your plan has a Roth feature, that is the first call to make, not the last.

The final regulations do provide relief for reasonable good-faith compliance through January 1, 2027, which means some plans will be working out their administration during 2026. Expect the possibility of corrections.

Why This May Actually Favor You

The instinctive reaction is that losing a deduction is a loss. For many women over 50, the arithmetic is less obvious than that.

Roth money grows tax-free and comes out tax-free, and Roth 401(k) balances are not subject to required minimum distributions. Both of those advantages compound with time — and time is the variable where women tend to have more of it. A woman retiring at 65 has a meaningfully longer statistical horizon than a man retiring at the same age, which means a longer stretch of tax-free growth and a longer period during which forced distributions would otherwise have driven up taxable income.

There is a second effect that matters specifically in widowhood. A married couple filing jointly moves into single-filer brackets when one spouse dies, and the surviving spouse — statistically more often the wife — can face materially higher tax rates on the same retirement income. Roth balances are insulated from that compression. Money that was going to be taxed eventually gets taxed now, at joint rates, rather than later at single rates.

Where the mandate genuinely hurts is cash flow in the current year. Losing the deduction on $8,000 of catch-up contributions raises your 2026 tax bill by whatever your marginal rate is on that amount — roughly $2,600 to $3,000 for most people in this income band. If you were relying on that deduction to manage estimated taxes or to stay under an income threshold that affects something else, the change is real and needs to be planned for rather than discovered in April.

What to Do Before Year-End

Pull your 2025 W-2 and look at the Social Security and Medicare wage boxes, not your total compensation. That figure, from the employer sponsoring your plan, is what determines your treatment.

If you are over the line, confirm with your plan administrator that a Roth source exists and that catch-up contributions are being routed to it correctly — administrative errors in the first year of a mandate are common, and this one has good-faith relief attached precisely because the IRS expects them. Then adjust your 2026 withholding or estimated payments for the lost deduction rather than absorbing the surprise at filing.

And if your income comes through a K-1 rather than a W-2, check before you restructure anything. You may already be exempt.