"The new regulations confirm that plans should determine impacted participants by looking at each participant's prior year Social Security earnings as reflected in Box 3 on Form W-[2] Participants whose earnings exceed $145,000 (or the COLA limit of $150,000, if applicable) in 2025 will be subject to the Roth catch-up requirement for plan years beginning in 2026. Employees who did not have Social Security earnings from the employer during the prior year will not be subject to the Roth catch-up requirement."  MORE >>