SECURE 2.0 Act Roth Mandate for 2026

This information has been modified to reflect 2026 values released by the IRS on Nov. 13. 

Starting Jan. 1, 2026, the federal SECURE 2.0 Act Roth mandate (signed into law on Dec. 29, 2022) applies to you if you are age 50 or older and your Social Security FICA wages (reported in Box 3 of your W-2) exceed $150,000 for 2025. This earnings test is repeated each year to determine if you are subject to the Roth mandate for the following year.

View the 2026 SECURE 2.0 Act Retirement Plan Changes presentation for the most detailed information from the U-M Benefits Office. To hear the audio, hover your cursor over the gray speaker graphic at the lower righthand side of the screen, then click on the black arrow just below and to the left of the speaker graphic.

What Changes

  • You may no longer make pre-tax age 50 catch-up contributions to the 403(b) SRA and 457(b); you can only make these contributions as Roth, and they can be made only by adding the new SECURE 2.0 Act Roth 403(b) SRA contribution and the new SECURE 2.0 Act Roth 457(b) contribution as additions to your existing contributions. 
  • Age 50 catch-up contributions are those you make to the 403(b) SRA*** and/or 457(b) in excess of the $24,500 general limit for 2026. 
  • The age 50 catch-up allows you to contribute up to an additional $8,000 to each plan, increasing the limit to $32,500. It increases the limit by $11,250 or a total of $35,750 for each plan if you are age 60-63. 
  • The Roth mandate does not affect your 5% contribution or the 10% university contribution to the Basic Retirement Plan. The catch-up limit returns to $32,500 for those age 64 and older.

If You Have Questions

Consult the following frequently-asked questions web pages:

How Do You Contribute and What Happens Next

  • Pre-tax
  • Roth
  • Pre-tax and Roth

More Resources

Read the SECURE 2.0 Act Enrollment Guide and Worksheet

2026 Limits
Plan General Limit* Age 50 Catch-up Limit** Age 60-63 Catch-up Limit**
403(b) SRA*** $24,500 $32,500 $35,750
457(b) $24,500 $32,500 $35,750
Total $49,000 $65,000 $71,500

* Contributions up to the general limit of $24,500 may still be made pre-tax and/or Roth.

** The age 50 catch-up allows you to contribute up to $8,000 if you are age 50 by Dec. 31, 2026, in addition to the general limit of $24,500, for a total of $32,500. It allows you to contribute up to an additional $11,250 if you are aged 60-63 by Dec. 31, 2026, for a total limit of $35,750. Catch-up contributions can no longer be made pre-tax starting in 2026 if the Roth mandate applies to you. Catch-up contributions can be made only as Roth.

*** Includes the 5% contribution you make (if any) to the 403(b) Basic Retirement Plan. If you are a voluntary participant, this is 5% on up to $360,000 in eligible earnings. If you are a compulsory participant (age 35 or older with two or more years of eligible service and appointment effort of 100%), this is your 5% contribution on earnings up to the FICA wage base ($184,500 for 2026).

You May Need to Act

The Roth mandate affects the 403(b) SRA*** if you want to contribute more than $24,500 to it. Likewise, the Roth mandate affects the 457(b) if you want to contribute more than $24,500 to it.

The following are two options if you want to contribute more than $24,500 to one or both programs, starting in 2026 if you are subject to the Roth mandate.

1. Add the SECURE 2.0 Act Roth Contributions

If you want to contribute more than $24,500 to the 403(b) SRA*** and/or 457(b), you need to add the new SECURE 2.0 Act Roth 403(b) SRA contribution and/or SECURE 2.0 Act Roth 457(b) contribution in January of 2026. This allows you to make age 50 catch-up contributions (up to $8,000 or up to $11,250 if age 60-63 to each plan), but these must be Roth and can no longer be pre-tax. Even if you already make only Roth contributions to the 403(b) SRA*** and/or 457(b), you must still add the new SECURE 2.0 Act Roth contributions to defer more than $24,500 to these programs.

OR

2. Shift Your Pre-tax Contributions

There is an alternative if you don’t want to make Roth age 50 catch-up contributions and prefer pre-tax contributions. You may be eligible to shift or reallocate pre-tax age 50 catch-up contributions (those made in excess of the $24,500 limit that must now be Roth under the SECURE 2.0 Act) across the 403(b) SRA*** and 457(b) if you don’t contribute to both plans.

This allows you to sidestep the Roth mandate by making pre-tax contributions across two different plans that each do not exceed $24,500 that otherwise would have to include Roth age 50 catch-up contributions if made to just one plan.

This strategy also works if you are enrolled in both plans but contribute less than $24,500 to one. Simply increase your pre-tax contributions in the plan to which you contribute less than $24,500. For this strategy to work, the amount of pre-tax age 50 contributions you are shifting, combined with the pre-tax contributions you already make to the receiving plan, must total no more than $24,500.

Key Takeaways

If you are subject to the SECURE 2.0 Act Roth mandate and you want to contribute more than $24,500 to the 403(b) SRA*** and/or 457(b), you need to add the new SECURE 2.0 Act Roth 403(b) SRA contribution and/or SECURE 2.0 Act Roth 457(b) contribution. 

Alternatively, you can shift or reallocate your pre-tax age 50 catch-up contributions that are going to be eliminated by the Roth mandate between the 403(b) SRA and 457(b). This allows you to continue making pre-tax contributions and sidestep the Roth mandate.

Your Current Status Options
You contribute $24,500 or more to both the 403(b) SRA*** and 457(b). Add the Secure Act Roth Contributions

You can make only age 50 catch-up contributions as Roth using the new Secure Act Roth 403(b) SRA contribution and/or Secure Act Roth 457(b) contribution.

1. You are enrolled in the 403(b) SRA or 457(b), but not both.

or

2. You contribute to the 403(b) SRA*** and the 457(b), but contribute less than $24,500 to one of them.

Shift Your Pre-tax Contributions

You may have the flexibility to shift or reallocate your age 50 pre-tax catch-up contributions that will be eliminated by the Roth mandate across the 403(b) SRA and 457(b).

This allows you to sidestep the Roth mandate by making pre-tax contributions across two different plans that each do not exceed $24,500 in contributions that otherwise would have to include Roth age 50 catch-up contributions if made to just one plan.

If You Decide to Act

If you decide to take action, you must make new elections through Wolverine Access. Follow the step-by-step guidance in the 2026 SECURE Act "how-to" presentation. To hear the audio, hover your cursor over the gray speaker graphic at the lower righthand side of the screen, then click on the black arrow just below and to the left of the speaker graphic.

Priority of Paycheck Deductions

For information about how the SECURE Act 403(b) SRA and SECURE Act 457(b) contributions are deducted relative to your other benefits deductions, view the "Priority of Deductions Taken From Your Pay" section on the Contribution Limits web page