Secure Act 2.0 Mandatory Roth Catch-Up for High Earners

Reference Number: NFC-26-1767814853
Published: January 7, 2026
Effective: Pay Period 25, 2025

Summary

On December 29, 2022, the Setting Every Community Up for Retirement Enhancement Act of 2022 (SECURE Act 2.0) was signed into law. The SECURE Act 2.0 builds on the SECURE Act of 2019 and introduces several changes affecting the Thrift Savings Plan (TSP).

Prior to SECURE Act 2.0, catch-up contributions to a qualified retirement plan could be made on a traditional (pre-tax) or Roth (after-tax) basis. Section 603 of SECURE Act 2.0 (Elective Deferrals Generally Limited to Regular Contribution Limit) states that beginning on January 1, 2024, a participant’s catch-up contributions must be Roth if the participant’s wages-as defined in 26 U.S. Code (U.S.C.) § 3121(a) in the preceding tax year were above a certain threshold. Catch-up contributions for participants whose wages were at or below that threshold can continue to be made on a traditional (pre-tax) or Roth (after-tax) basis. This threshold is expected to be adjusted annually for inflation.

Participants who are aged 50+ with prior-year wages less than or equal to $150,000 can make traditional or Roth catch-up contributions according to the contribution election on file. Participants who are aged 50+ with prior-year wages greater than $150,000 can only contribute Roth catch-up contributions regardless of the participant's contribution election on file.

Note: Beginning in 2026, $150,000 is the threshold that will be used to determine the type of catch-up contributions participants will be allowed to make annually. Per section 603, catch-up eligible participants whose wages are over the defined threshold can only make Roth catch-up contributions.

Affected Systems

System	System Impact
Employee Personal Page (EPP)	Modified the TSP Catch-Up (Federal and non-Federal) page to include an additional statement.
Insight	Created the Insight Common Report TSP Secure 2.0 Wages Data.

Implementation

Agencies should update their payroll office's processes, procedures, and systems to ensure participants send the appropriate catch-up contribution type in order to be compliant with the provisions set forth in section 603. The Agency must confirm their employees are able to make and change contribution elections as needed.

Elected Deferral Limit (section 402(g)) for 2026: $24,500.
Catch-up Limit (section 414(v)) for 2026: $8,000.
Higher Catch-up Limit for 2026: $12,000.
Section 402(g) limit + the regular catch-up limit 2026: $32,000.
Section 402(g) limit + the higher catch-up limit 2026: $36,000.

Impacted Retirement Plan codes are:

01-Federal Employees Retirement System (FERS)
02-Civil Service Retirement System (CSRS)
98-FERS Roth
99-CSRS Roth
NAFI 401K Plan Codes
- TA
- TC
- TD
- TE
- TF
- EE

Note: Employees who are eligible to make the catch-up contributions via Roth IRAs will need to (1) establish a Roth contribution if they do not have currently in place or (2) adjust the amount being deducted for their Roth IRA if they already have one established to meet the desired catch up amount.

It is important to understand that the National Finance Center will not automatically roll over any amount over the elected deferral limit to a Roth contribution on behalf of the employee. The employee must elect all contributions and amount.

EPP

On the TSP Catch-Up Selection tab on the Thrift Savings Plan Catch-Up (Federal and Non-Federal) Page, EPP will be modified to include the following additional statement:

TSP SECURE Act 2.0, Section 603: Impacts to Thrift Savings Plan (TSP) Catch-Up Contributions which states a participant’s catch-up contributions must be Roth if the participant’s FICA wages (as defined in 26 U.S.C. § 3121(a)) in the preceding tax year were above a certain threshold. This is regardless of the participant’s contribution elections on file.

Insight

A new Insight common report, TSP Secure 2.0 Wages Data, has been created to assist you in identifying employees that meet the criteria for the guidance.

The following information is contained in the new report:

Social Security number
Name
Date of birth
Age
Agency code
Prior year Medicare wages
Employee has a Roth account (Yes or No)

The new report will use the following report query information:

Filter Report by: Dept, Agency and/or personnel office identifier (POI).
Employee has a Roth account.
Employee age is greater than or equal to 50 in the calendar year.
Employee prior year Medicare wages are greater than or equal to $150,000 in the calendar year.

Resources

For more information about Secure Act 2.0 Mandatory Roth Catch-Up for High Earners, please see Higher Catch-Up Limits to the Thrift Savings Plan (TSP) for Age 60-63.

The EPP Procedure, which is available online on the NFC website, is being updated to include the information in this bulletin. To view this procedure, select HR and Payroll Clients from the MyNFC drop-down menu on the NFC Home page. At the HR and Payroll Clients page, select the Publications tab and select NFC System Documentation from the Publications Library section. Select the applicable procedure manual.

Inquiries

For questions about NFC processing, authorized Servicing Personnel Office representatives should contact the NFC Contact Center at 1-855-NFC-4GOV (1-855-632-4468) or via the customer service portal at ServiceNow Portal for Federated Users and at ServiceNow Portal for Non-Federated Users.