Our Employee Benefits attorneys offer insights into the tax and benefits aspects of the OBBBA that employers should focus on in 2026. We review key employer obligations and planning considerations for 2026, highlighting where temporary transition relief applied in 2025 and should not be mistaken for lasting flexibility.
Mandatory Roth Catch-up
IRS Issues Final Regulations on Mandatory Roth Catch-Up Contribution Ahead of January 1, 2026 Implementation Date
By Tenechia D. Lockhart on
- Generally, plan sponsors should be prepared to implement the Roth catch-up rule for taxable years beginning after December 31, 2025 (i.e., January 1, 2026, for calendar year plans). This will require coordination with ERISA counsel, the company’s payroll provider, and the plan’s recordkeeper and third-party administrator.
- Be prepared to discover mistakes and correct them