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An Employer's Practical Guide to 401(k) Plan Catch-Up Contribution Changes for 2026
Baker Donelson Link to more items from this source
[Guidance Overview]
Nov. 7, 2025

"These steps should be taken by December 31, 2025: [1] Ensure systems will identify 'High Earners' ... [2] Confirm payroll is set to withhold catch-up contributions for High Earners as after-tax contributions. [3] Determine whether the plan will administer catch-up contributions as deemed elections or require affirmative election. [4] Confirm payroll and plan recordkeeping systems communicate wage data correctly and can segregate contribution types. [5] Communicate with participants."  MORE >>

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