SECURE Act 2.0: Catch-Up Contributions

The aim of SECURE Act 2.0 is to better strengthen the American retirement system by improving ways Americans can save for retirement.
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According to the Federal Reserve’s 2022 Survey of Consumer Finances, 54.4% of Americans do not have a dedicated retirement savings account. The original SECURE Act passed in 2019 was designed to help more Americans save for retirement. Three years later, SECURE Act 2.0 updated the existing act and added over 90 new provisions enhancing the way people can save for retirement. Highlights of the updated act are: greater contribution limits, raising the age at which people must begin to take their Required Minimum Distributions (RMDs), requiring new retirement plans (such as 401(k)s and 403(b)s) to automatically enroll employees at a set contribution rate, and more.

After Secure Act 2.0 passed in 2022, there were many issues and sections that either needed reworking or did not go into effect immediately. But as we turn our attention to the new year, we’d like to remind our clients that one of the changes to employer sponsored retirement accounts is set to go into effect in 2026 and we want you to be as prepared as possible to take advantage of these changes.

Employer Sponsored Retirement Accounts and Catch-Up Contributions

For tax year 2025, individuals younger than 50 can contribute up to $23,500 to their employer sponsored retirement account.

For individuals 50 years of age or older, additional catch-up contributions up to $7,500 can be made to tax-deferred accounts such as a 401(k) or tax-free growth accounts such as a Roth 401(k). These special catch-up limits may also apply to 403(b) and 457(b) plans. SIMPLE IRA and SIMPLE 401(k) plans have different contribution limits.

Additionally, for individuals who are between the ages of 60 and 63, the catch-up contribution limit increases to $11,250. Yes, it’s a very small and specific age window, but it reiterates the legislation’s aim to help individuals grow retirement savings.

See the figure below for a detailed chart of employer sponsored plans and their contribution limits. As with all tax related topics, we encourage you to speak with your CPA for additional information.

Secure Act 2.0 Catch-Up Contribution Table

High-Income Earner Contribution Exceptions Go into Effect in 2026

Starting in 2026, individuals who have gross yearly FICA wages that are higher than $145,000 will no longer have the option to make their catch-up contributions into the tax-deferred side of their employer retirement plans. Why does this matter? For many high-income individuals, putting money into the tax-deferred side of their retirement plan has been one strategy to lower their annual tax obligation. However, with this change, high-income earners will have to allocate their catch-up contribution to the designated Roth account of their retirement plan (if their plan offers one) and pay taxes upfront. 

Note: if you are in this group, we recommend speaking with your Retirement Plan Administrator to determine whether a Roth account option available or can be added to your plan.

While this change does eliminate the choice between tax-deferred contributions or Roth contributions for high-income earners, you may choose to look at this as a forced positive. Why? Because you can’t be taxed twice on retirement income (provided you withdraw it properly). While you will still have to pay taxes up front on the Roth contribution to your employer sponsored retirement plan, you will never have to pay taxes on those funds again. As demonstrated in the Tax Control Triangle (see figure below), tax-free growth in employee retirement accounts makes up just one side of the triangle.

Tax Control Triangle

At CWM, when we look at retirement planning and how to pay for expenses in retirement, we like to have choices of where that money can come from. Making sure that you have assets on each side of the triangle can help ensure that you have a level tax obligation in retirement. For instance, if large unforeseen expenses happen, you will not be forced to take funds from a taxable source if you have a tax-free source funded and ready.

Keep in Mind…

One of the reasons the rollout of these changes has been delayed until 2026, was to give employers time to amend their employee retirement plans to add a Roth option. However, it should be noted that employers were not required by the Act to offer a Roth option to available retirement plans, so some technically eligible individuals will not be able to take advantage of catch-up contributions.

Additionally, if you are self-employed and earn more than $145,000 you are not subject to this rule and can make contributions as detailed in the previously shown chart.

If you are interested in a more robust conversation about changes stemming from SECURE ACT 2.0 or the “Tax Control Triangle”, please click here to schedule a conversation or contact us at (425) 778-6160.

Comprehensive Wealth Management, LLC (CWM) is an SEC registered Investment Advisor and Pacific Northwest wealth management firm that partners with clients to articulate and help achieve their financial goals as prudently as possible. Our high-touch, client-focused investment planning and implementation makes us the first call for executives, business owners, and other thoughtful investors to help strengthen their financial health holistically and intentionally, managing risk while pursuing long-term gains.

Comprehensive Wealth Management, LLC (CWM) does not provide legal or tax advice. The information herein is general and educational in nature and should not be considered legal or tax advice. Tax laws and regulations are complex and subject to change, which can materially impact investment results. CWM makes no warranties with regard to such information or results obtained by its use, and disclaims any liability arising out of your use of, or any tax position taken in reliance on, such information. Consult an attorney or tax professional regarding your specific situation.

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