All 401(k), 403(b)/TDA, and governmental 457(b) plans offering catch-up contributions are impacted. SARSEPs, SIMPLEs, and Starter 401(k)/403(b)s are excluded.

No, adding the Roth contribution feature is not required. It is optional and up to the plan sponsor to decide whether to include it. However, if the plan wants to allow high earner participants to make catch-up contributions, the Roth feature must be added, as these contributions will be required to be made as Roth starting in 2026.

A Board resolution is required only if the employer’s governing authority to amend the plan resides with the Board of Directors. However:

• If the Board has delegated amendment authority to an officer or a committee (e.g., a Fiduciary and Benefits Committee), then the authorized person’s signature on the amendment is sufficient.
• For employers without a Board (such as partnerships, sole proprietorships, or churches), a Board resolution is not applicable.
• If the amendment is a mandatory compliance amendment (such as adding Roth catch-up under the Secure 2.0 Act), and the plan uses a Relius pre-approved document, the amendment will be adopted without requiring a Board resolution.
• For discretionary amendments (e.g., adding a Roth feature to a plan that does not currently have one), a separate amendment and Board resolution (or similar authorization) are required.
• Plan sponsors should confirm their governance structure and delegation of authority before proceeding.

No. Plan sponsors cannot force all catch-up contributions to be subject to the Secure 2.0 Act rule. Under the new regulation, only Highly Paid Individuals (HPIs) — those with FICA wages in 2025 over $150,000 — must make catch-up contributions as Roth. Plans may permit all participants, including those below the HPI threshold, to voluntarily elect Roth catch-up contributions. Sponsors may also choose the “deemed Roth” approach for HPIs, provided participants have an effective opportunity to opt out.

Participants who qualify:

• Must be in a plan that permits catch-up contributions.
• Must have earned more than $150,000 in FICA wages in 2025 for the employer sponsoring the plan (amount is indexed annually).
• Must turn age 50 or older by the end of the 2026 calendar year.
• Note: These individuals are considered Highly Paid Individuals (HPIs) and must make catchup contributions as Roth.

The difference between the two classifications:

• HPI (Roth Catch-Up): $150,000+ in FICA wages in 2025 with the same employer.
• HCE (Nondiscrimination Testing): $160,000+ in plan compensation in 20for the prior plan year.
• Both thresholds are indexed annually for inflation

Sponsors must:

• Identify these individuals annually; participants may change from one year to the next.
• Work with payroll providers to ensure proper coding and proper enforcement of the rules (e.g. the payroll system should not withhold traditional catch-up from participants who are not allowed to have traditional catch-up).
• Report these participants to Mutual of America annually via work orders.
• If the sponsor chooses to offer Roth Catch-Up contributions, the plan must be amended to permit them, provided Roth is not already enabled.
• Update plan documents and SPDs by December 31, 2026.

Mutual of America will not validate the Roth Catch-Up Only status sent by the plan sponsor. For participants who are reported as Roth Catch-Up Only, Mutual of America adds a layer of validation but does not control payroll coding. Contributions may be rejected, or erroneously allowed, if improperly coded, and manual intervention may be required.

To avoid any disruption for affected employees, plan sponsors are encouraged to immediately notify Mutual of America of their intent to add the Roth Contribution feature before January 1, 2026. If a sponsor chooses to offer Roth, they must submit an amendment request as soon as possible to have that feature added to their plan. To initiate this process, sponsors should contact their Client Relationship Manager (CRM).

Additional benefits include:

• Tax Diversification: Participants can choose between pre-tax and after-tax savings strategies.
• Attract and Retain Talent: Roth is appealing to younger employees or those expecting higher income in retirement.
• RMD Flexibility: Roth assets held in a plan are excluded from Required Minimum Distributions.
• Minimal Administrative Burden: Most systems support Roth with minimal changes; Mutual of America does not increase recordkeeping fees for adding Roth.
• Participant Engagement Opportunity: A chance to educate participants on retirement planning and tax-smart saving strategies.

Plan sponsors should confirm their plan document provisions and ensure amendments reflect these limits. For 2026 the contribution limits are:

•  Under age 50: $24,500
• Age 50+: $32,500 ($24,500 + $8,000 catch-up)
• Age 60–63 (“Enhanced Catch-Up”): $35,750 (if plan allows age 50 catch-up -- $24,500 + $8,000 catch-up + $3,250 enhanced catch-up)
• Age 64+: $32,500 ($24,500 + $8,000 catch-up)
• Important Note: The IRS initially set the super catch-up limit at 150% of the regular catch-up amount. Going forward, it will be adjusted for inflation independently, so it will not always equal 150%. For 2026, the limit did not increase under the IRS formula.

Plan sponsors may deem all HPIs’ catch-up contributions as Roth.

• HPIs must have an effective opportunity to elect otherwise.
• If no election is made and pre-tax contributions are deposited, they must be refunded or recharacterized as Roth. Note, pursuant to the final IRS regulation (effective 1/1/27), the ability to correct under either the W-2 recharacterization or the internal rollover method is permissible only if the plan provided for deemed Roth election.

The correction deadlines are:

• March 15: For ADP-triggered catch-up contributions (401(k)/401(a) plans).
• April 15: For 402(g)/401(a)(30) excess contributions.
• June 30: If plan has Eligible Automatic Contribution Arrangement (EACA).
• December 31: If catch-up contributions are not recharacterized as Roth, it becomes an operational failure.

Special exemption: Excess catch-up of $250 or less can remain pre-tax without further action.

Annual notice must be provided to impacted HPIs, giving them the right to affirmatively elect Roth or pre-tax treatment (if allowed).

Payroll providers should:

• Aggregate FICA wages from all payroll providers if changed during the year.
• Combine wages for asset purchases between employers and plan sponsors.

If an HPI who is eligible for catch-up makes Roth contributions prior to reaching the standard 402(g) limit (non-catch-up), that participant is able to make pre-tax catch-up contributions, up to the lesser of the catch-up limit and the amount of non-catch-up Roth contributions made. Mutual of America is working on automating this process to the extent possible, but in certain cases, it is possible that plan sponsors may need to contact their CRM for assistance with the contribution posting. Plan Sponsor Responsibilities:

• Ensure payroll systems correctly classify catch-up contributions for HPIs.
• If an HPI elects pre-tax catch-up contributions and the plan does not allow “deemed” Roth treatment (or the participant opts out), any pre-tax catch-up amounts must be refunded to the participant if they cannot be recharacterized as Roth.
• Sponsors should provide timely notices to HPIs and coordinate with payroll providers to prevent operational errors.