A Note: Roth Catch-Up Mandate Effective as of January 1, 2026

The final regulations on the SECURE Act's Roth catch-up mandate created some confusion over whether the IRS had again delayed the requirement that catch-up contributions for certain high-income employees be treated as Roth contributions. The IRS decided to delay the effective date of the final regulations themselves, so the regulations are not effective until January 1, 2027. The preamble to the regulations do, however, specifically state that the regulations are not extending or modifying the existing transition period. The IRS granted an administrative period so that the catch-up mandate (originally set to be effective beginning in 2024) does not become effective until 2026. Beginning with the 2026 tax year, employers are required to comply with the Roth mandate on a reasonable, good faith basis until the effective date of the regulations themselves. For more information on the Roth catch-up mandate, visit Tax Facts Online. Read More: Link to Q3761. Note: Q is updated.