For our third installment in this series on the mandatory Roth catch-up provision taking effect in 2026, we have compiled a list of the most frequently asked questions we have received on this topic. This update also reflects the final regulations issued on September 15, which have now been incorporated into the FAQs.

One recurring area of confusion relates to the effective date of the new rules. As addressed in the FAQs, while the final regulations become effective in 2027, the Roth catch-up mandate itself remains effective beginning January 1, 2026. Accordingly, employers must comply with the mandate in 2026 using a good faith effort and then follow the finalized regulatory requirements beginning in 2027.

Because of the significance and wide-ranging impact of these provisions, we will continue to provide additional guidance to help clients navigate this important change. Upcoming installments in this series will address items such as the required policies and procedures for certain correction methods, communication templates employers may use to notify affected participants, and key considerations related to deferral elections.