Overview

Under current law, an employee can choose whether their age 50+ contributions or new age 60-63 contributions to a 457(b), 403(b) or 401(k) retirement plan are made on a pre-tax or Roth basis.

Provision 603 of the SECURE 2.0 Act requires all age-based contributions to 457(b), 403(b) or 401(k) retirement plan be made on a Roth basis for all employees whose wages (as defined for Social Security FICA tax purposes - i.e., Box 3 of form W-2) for the preceding calendar year exceed $150,000 (indexed for inflation).

All employees with wages below $150,000 for the preceding calendar year must be given the option (but are not required) to make age-based contributions on a Roth basis.

Age based catch-up contribution 2026 limits

Additional retirement plan contributions over the standard IRS maximum contribution limit ($24,500)

Age 50+ - Employees may defer an additional $8,000 (annual limit maximum: $32,500)
Age 60-63 - Employees may defer an additional $11,250 (annual limit maximum: $35,750)

Roth contributions

Contributions that have already been taxed.

What this means

Employers who utilize the MNDCP must allow Roth after-tax contributions for all employees after January 1, 2026
In 2026, if an employee age 50+ exceeded the compensation threshold ($150,000) in the prior year and wishes to make age based contributions to their retirement plan, they must be made on a Roth after-tax basis.
Employer payroll departments should work with their payroll providers and third party administrators to ensure contributions made above the standard IRS maximum contribution limit for age-based contributions are submitted as Roth after-tax.
On an annual basis, we recommend you provide Voya a Mandatory Roth Indicator (MRC) that details those employees who exceeded the prior-year compensation threshold ($150,000 in FICA compensation in 2025). With that information on file, Voya can provide meaningful warnings to your payroll department/provider. These warnings are intended to prevent and/or alert payroll representatives about instances where additional contributions need to be made as Roth.

Employer Job Aid

For more information on this mandatory provision of the SECURE 2.0 Act.

Instructions

Provide Voya with a Mandatory Roth Indicator (MRC) for impacted employees.

Employee Communication

For those impacted employees that you have identified with a Mandatory Roth Indicator (MRC), MSRS will send a confirmation informing them of this new contribution requirement.

MSRS will also send impacted employees a letter twice a year (Spring & Fall).