Command Center — (k) Suite

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Notes

Cost-of-living adjustments for 2026 were announced by the IRS in Notice 2025-67 (November 13, 2025). The 401(k) deferral limit rose $1,000 to $24,500, and the mandatory Roth catch-up wage threshold under SECURE 2.0 §603 took effect at $150,000.

Provision	2025	2026	Change
Employee Deferrals
401(k) / 403(b) / 457(b) / TSP Deferral	$23,500	$24,500	↑ $1,000
Catch-Up Contribution (age 50+)	$7,500	$8,000	↑ $500
Super Catch-Up (ages 60–63)	$11,250	$11,250	unchanged
Roth Catch-Up Wage Threshold (§603)	$145,000	$150,000	NEW 2026
Employer & Total
Annual Additions Limit (§415(c))	$70,000	$72,000	↑ $2,000
Annual Compensation Cap (§401(a)(17))	$350,000	$360,000	↑ $10,000
Gov't Grandfathered Comp Cap	$520,000	$535,000	↑ $15,000
Testing Thresholds
Highly Compensated Employee (§414(q))	$160,000	$160,000	unchanged
Key Employee Officer (§416(i))	$230,000	$235,000	↑ $5,000
SIMPLE Plans
SIMPLE IRA / SIMPLE 401(k) Deferral	$16,500	$17,000	↑ $500
SIMPLE Catch-Up (age 50+)	$3,500	$4,000	↑ $500
SIMPLE Super Catch-Up (60–63)	$5,250	$5,250	unchanged
Individual Retirement Accounts
Traditional & Roth IRA Contribution	$7,000	$7,500	↑ $500
IRA Catch-Up (age 50+)	$1,000	$1,100	↑ $100
Other
Social Security Wage Base	$176,100	$184,500	↑ $8,400
PLESA Annual Contribution (§127)	$2,500	$2,600	↑ $100

Source: IRS Notice 2025-67 (released November 13, 2025); SSA 2026 COLA Announcement. Verify at irs.gov before acting on these figures.

Under SECURE 2.0 §603, participants earning above the wage threshold must make their catch-up contributions on a Roth (after-tax) basis. The rule took effect January 1, 2026 after IRS Notice 2023-62 extended the original 2024 deadline. Final regulations are expected in 2026.

Applies to participants whose prior-year Box 3 Medicare wages from the same employer sponsoring the plan exceeded $145,000 (2025) → $150,000 (2026). Indexed annually.

Practitioner note: Self-employment income doesn't count. Wages from a prior or unrelated employer don't count toward the current plan's threshold.

Applies to 401(k), 403(b), and governmental 457(b) plans. Not applicable to SIMPLE IRAs, SIMPLE 401(k)s, or non-governmental 457(b) plans.

A plan must offer the Roth feature to permit any catch-up contribution from affected participants. If the plan does not have a Roth option, no catch-up contributions are permitted from anyone above the threshold.

Practitioner note: If a plan amendment adds Roth, the "deemed Roth election" under proposed regs (Jan 2025) allows the recordkeeper to automatically re-characterize the catch-up.

The catch-up amount is included in W-2 wages in the year of contribution (no current-year deduction). In exchange, qualified future withdrawals — including earnings — are tax-free, matching standard Roth 401(k) treatment.

(1) Confirm plan has Roth 401(k) feature; amend if not. (2) Coordinate with recordkeeper/payroll to identify participants above threshold. (3) Communicate the change to affected participants before the plan year begins.

Practitioner note: Many recordkeepers now support an "auto-Roth catch-up" flag that handles the re-characterization without participant election.

SIMPLE IRAs and SIMPLE 401(k)s got their own catch-up increase under SECURE 2.0 (§109/§117) but are not subject to the mandatory Roth rule. 2026 SIMPLE catch-up is $4,000 (age 50+) or $5,250 (ages 60–63 super catch-up).

Sources: SECURE 2.0 Act §603 (enacted Dec 29, 2022); IRS Notice 2023-62 (transition relief); Proposed Treas. Reg. §1.414(v)-2 (Jan 10, 2025).

SECURE 2.0 made four significant changes to the RMD framework: the starting age rose from 72 to 73 (and will rise to 75 in 2033), the excise tax was cut in half, Roth 401(k)s became exempt from lifetime RMDs, and surviving spouses gained a new deferral election.

Participants who turn 72 after 2022 begin RMDs at age 73. Participants who turn 74 after 2032 begin RMDs at age 75. First RMD is deferred to April 1 of the year following the applicable age (the "Required Beginning Date").

Practitioner note: Born 1951–1959 → age 73. Born 1960+ → age 75. Double-check the recordkeeper's RBD calculations — many platforms were still using 72 into 2024.

Starting 2024, designated Roth accounts in 401(k)/403(b) plans no longer require lifetime RMDs, aligning with Roth IRA treatment. Previously, Roth 401(k) balances were subject to RMDs at the participant's RBD unless rolled to a Roth IRA.

Practitioner note: Removes the historical incentive to roll Roth 401(k) to Roth IRA prior to RBD. Post-death RMD rules still apply to beneficiaries.

The penalty for missing an RMD dropped from 50% to 25% of the shortfall. If the participant corrects the missed RMD and files Form 5329 within the 2-year correction window, the penalty is further reduced to 10%.

Practitioner note: Correction window runs from the end of the year the RMD was missed. The reasonable-cause waiver (Form 5329 Part IX) still exists on top of these reductions.

Beginning 2024, a surviving spouse beneficiary may elect to be treated as the deceased employee for RMD purposes. This permits the spouse to defer RMDs until what would have been the deceased's RBD, and use the Uniform Lifetime Table instead of Single Life.

Practitioner note: Most valuable when the surviving spouse is older than the deceased. The plan must be amended to permit this election — it's not automatic.

Participants still actively employed by the plan sponsor (and who are not 5%+ owners) may defer plan RMDs until the April 1 following the calendar year in which they actually retire — regardless of age.

Practitioner note: Does NOT apply to IRAs or to prior-employer balances. The 5%+ owner rule applies if ownership at any time during the plan year including the year the employee reaches the applicable age.

Annual RMD = (prior-year 12/31 balance) ÷ (life-expectancy factor from the IRS Uniform Lifetime Table). First RMD: April 1 following attaining RMD age. Subsequent RMDs: December 31 each year.

Practitioner note: Deferring the first RMD to April 1 means two RMDs hit in one tax year. Consider taking the first RMD in the attaining year to smooth the tax impact.

Sources: SECURE 2.0 Act §§107, 302, 325, 327; IRC §401(a)(9); Treas. Reg. §1.401(a)(9); IRS Publication 590-B; IRS Notice 2022-53.

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Regulatory Calendar — All Upcoming Dates

IRS Contribution Limits — 2025 vs 2026

Mandatory Roth Catch-Up Rules

Required Minimum Distributions — SECURE 2.0 Rules

SECURE 2.0 — Key Provisions Reference

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